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IRS Reduces Built-in Gains Tax Period for REITs to Five Years

By Amanda Wilson on Jan 18, 2017 in Real estate, Congress, International, IRS, path act, REIT, S Corporation, Tax

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...

What Is Carried Interest?

By Amanda Wilson on Oct 19, 2016 in carried interest, government, International, IRS, lowndes, medical marijuana, Partnership Tax, Tax

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...

IRS Reverses Position on Bad Boy Guarantees

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

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...