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 common...

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...

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...