By: Amanda Wilson In the 1990s, Treasury issued proposed regulations under Regulation Section 1.337(d)-3 commonly known as the "May Company" regulations. These proposed regulations dealt with situations in which a partnership owned stock of a...

By: Amanda Wilson Last week, I was at the ABA Tax Section meeting in DC, and one refrain that I heard over and over is that tax reform is a major priority for Congress. The Obama administration has basically shut down the possibility of personal tax...

By: Amanda Wilson In late April, Senator Orrin Hatch introduced Senate bill 915, the Real Estate Investment and Jobs Act of 2015. When a foreign person invests in property in the U.S., that person is subject to U.S. tax when he/she/it disposes of...

By: Amanda Wilson A recent proposal by U.S. Congressman Jason Chaffetz, the Chairman of the Committee on Oversight and Government Reform, would eliminate the tax-exemption under Internal Revenue Code section 501(c)(6) for professional sports leagues...