Alston & Bird Tax Blog

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 Act
  • Effects on Subpart F, GILTI, and other rules

For the full advisory, click here.

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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Daniel Reach

About Daniel Reach

Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.

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George Abney

About George Abney

George Abney is a partner on the firm’s Tax Controversy Team, whose practice focuses on civil and criminal tax controversy matters. George has significant trial and appellate experience gained from years as a federal prosecutor with the Tax Division of the U.S. Department of Justice in Washington, D.C., and as an assistant U.S. attorney in the Northern District of Florida.

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Mark Williamson

About Mark Williamson

Mark Williamson is a partner and chair of Alston & Bird’s Wealth Planning and Exempt Organizations Teams. He is a Fellow of the American College of Trust and Estate Counsel and practices in the areas of estate planning and federal taxation.

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