Taxing times blog header

The End of Leveraged Partnership Transactions?

By Amanda Wilson on Sep 21, 2016 in IRS, medical marijuana

By:  Amanda Wilson If a partner contributes property to a partnership, and within a two year period, receives cash from that partnership, the tax rules generally treat that as a disguised sale of property by the partner to the partnership.  One...

Regulations Finalized on REIT Real Property Rules

By Amanda Wilson on Sep 16, 2016 in Other

By: Amanda Wilson The Department of Treasury and IRS have finalized the regulations defining "real property" for purposes of the REIT rules. The regulations essentially adopt the proposed regulations, which I previously discussed here. It is nice to...

IRS Reverses Position on Bad Boy Guarantees

By Amanda Wilson on Apr 19, 2016 in IRS, Tax, International

By:  Amanda Wilson As previously discussed (here), the IRS recently released a chief counsel advice memorandum that concluded that bad boy guarantees turned what would otherwise be a nonrecourse debt into a recourse debt for Section 752 purposes. ...

New Temporary Inversion Regulations

By Amanda Wilson on Apr 6, 2016 in government, International, lowndes, Tax

By:  Amanda Wilson The IRS once again is targeting inversions, and this time there have been immediate tangible results. The IRS issued temporary regulations on Monday targeting inversion transactions.  An inversion occurs where a foreign...