In a bipartisan effort to pass new legislation to extend and provide for increased reporting under the Qualified Opportunity Zone (QOZ) Program, on April 7, 2022, members of Congress introduced
Continue Reading Bipartisan Proposed Legislation Released for Qualified Opportunity Zone Investments
On Jan. 7, 2021, the Department of Treasury and IRS issued final regulations (the Regulations) that provide guidance to the “carried interest” rules under Section 1061 of the Internal Revenue
Continue Reading 3-Year Holding Period Rule for ‘Carried Interests’ Addressed in IRS Final Regulations
On July 31, 2020, the Department of Treasury and IRS issued proposed regulations that provide guidance to the “carried interest” rules under Section 1061 of the Internal Revenue Code. Long-term
Continue Reading 3-Year Holding Period Rule for ‘Carried Interests’ Addressed in IRS Proposed Regulations
On June 5, 2020, the Internal Revenue Service (IRS) issued Notice 2020-39 providing relief for Qualified Opportunity Funds (QOFs) and their investors (QOF investors), and clarified previously issued relief to
Continue Reading IRS Provides COVID-19 Relief for Qualified Opportunity Funds and Their Investors
Recently proposed IRS regulations would significantly affect tax on income from international cloud transactions and electronic transfers of digital content. Accordingly, CFOs should review the structure of agreements involving such
Continue Reading IRS Aims to Catch Up to Tech Advancements
On Aug. 9, 2019, the IRS issued proposed regulations (Proposed Regulations) addressing the U.S. federal income tax treatment of cross-border cloud transactions. The Proposed Regulations will not become effective until
Continue Reading IRS Clarifies U.S. Tax Treatment of Cross-Border Cloud and Other Online Transactions in Proposed Regulations