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IRS No Rule Policy Expected to Cool Down Spin-offs

By Amanda Wilson on Sep 16, 2015 in Other, Real estate, International, IRS, REIT, treasury

By:  Amanda Wilson On Monday, the IRS released Notice 2015-59.  In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where (i)...

Proposed Regs Shutdown Exception for Offshore Transfers of Foreign Goodwill

By Amanda Wilson on Sep 15, 2015 in International, IRS, treasury

By:  Amanda Wilson Yesterday, the IRS and Treasury released proposed regulations governing the treatment of certain transfers of foreign goodwill and going concern value. When a U.S. person contributes property to a foreign corporation, Section 367...

Further Crackdown on Offshore Corporations

By Amanda Wilson on Sep 2, 2015 in Foreign Operations, International, IRS, Partnership Tax, treasury

By:  Amanda Wilson In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships.  These regulations provide that debt held by foreign...

Senator Targets Carried Interests

By Amanda Wilson on Jun 25, 2015 in capital gain, carried interest, government, International, IRS, Obama care, Tax, tax code, tax rate, treasury

By:  Amanda Wilson Yesterday, Senator Al Franken sent a letter to the Department of Treasury taking aim at "carried interest" income.  In the letter, Senator Franken asked the IRS to revise  Form 1065 (the tax return form for partnerships) to...