By: Amanda Wilson One of the key benefits of a real estate investment trust ("REIT") is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid deduction on...

By: Amanda Wilson During the second presidential debate, one of the few things that both candidates agreed on was doing away with carried interest as part of their proposed tax changes. But they never explained what it is. So what was is carried...

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....

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 corporation...