Alston & Bird Tax Blog

Clay Littlefield

About Clay Littlefield

Clay Littlefield, a partner based out of Alston & Bird’s Charlotte and New York offices, is a member of the Federal & International Tax Group. Clay concentrates his practice on tax issues confronted by underwriters, issuers, and investors participating in structured finance transactions, including mortgage and asset-backed securitizations, REMICs, CLOs, REITs, and similar structures.

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Crypto Asset Industry Cautious as Biden Administration Proposes New Reporting Rules

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Our Federal Tax Group mines recent legislative proposals for amendments that could change the way crypto assets are reported – and taxed. Proposed amendments to Section 6045The status of mining and staking activitiesNew proposals from the House Ways and Means CommitteeConcerns and uncertainties surround any discussion of rewriting crypto tax law Read the full advisory here. [...]Read more

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

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Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance. Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]Read more

IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts

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Yesterday, our Federal Tax Group discussed a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related modifications).

What safe harbors are available?
Which mortgage loan forbearance programs are eligible?
How are “related modifications” treated?

Alston & Bird has formed a multidisciplinary task force to advise clients on the business and legal implications of the coronavirus (COVID-19).

Read the full advisory here. [...]Read more