Harry A. Boris

May 17, 2024 | mondaq.com | Michelle Jewett |Matthew McDonald |Harry A. Boris

On April 25, 2024, the US Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations (T.D. 9993) (the "final regulations") concerning the election to transfer certain tax credits under section 6418 of the Internal Revenue Code (the "Code").1 The final regulations are of interest to public and private real estate investment trusts ("REITs") that currently have, or are contemplating the implementation of, clean energy programs.

May 15, 2024 | jdsupra.com | Harry A. Boris |Michelle Jewett |Matthew McDonald

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations”) concerning the election to transfer certain tax credits under section 6418 of the Internal Revenue Code (the “Code”).1 The final regulations are of interest to public and private real estate investment trusts (“REITs”) that currently have, or are contemplating the implementation of, clean energy programs.

May 2, 2024 | jdsupra.com | Harry A. Boris |Jeffrey Bruns |Michelle Jewett

On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). The changes also affect the treatment of qualified foreign pension funds (QFPFs). The final regulations generally follow the proposed regulations issued in January 2023, with certain changes discussed below.

May 1, 2024 | lexology.com | Jeffrey Bruns |Michelle Jewett |Mark Leeds |Matthew McDonald |Sam Riesenberg |Harry A. Boris

On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). The changes also affect the treatment of qualified foreign pension funds (QFPFs). The final regulations generally follow the proposed regulations issued in January 2023, with certain changes discussed below.