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