• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

May 20, 2020 By Clay Littlefield, Daniel Reach, George Abney and Mark Williamson

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.

Filed Under: Uncategorized Tagged With: CARES Act, Controlled Entities, Deb-financed properties, GILTI, IRS, NAICS, NOLs, partnership, QPI, S Corp, Schedule K-1, Subpart F, TCJA, Treasury, UDFI

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.

[Read Bio]

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.

[Read Bio]

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.

[Read Bio]

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.

[Read Bio]

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?
  • California Dreaming of a Voluntary Compliance Program
  • Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care

Archives

Copyright © 2022 · Alston & Bird · All Rights Reserved. Privacy.