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IRS Issues Final Regulations Addressing Ownership Of Domestically Controlled REITs - Fund Management/ REITs

IRS Issues Final Regulations Addressing Ownership Of Domestically Controlled REITs - Fund Management/ REITs
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Proposed Regulations Would Impact Taxation of Investment in U.S. Real Estate by Non-U.S. Investors | King & Spalding

On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated. ....

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Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions | Proskauer - Tax Talks

Applies retroactively to effective date of CARES Act
Credit increased to 70% of qualified wages; cap on credit increased to $28,000. The CARES Act provided for a refundable payroll tax credit of 50% of certain “qualified wages”, capped at $5,000/employee (50% of up to $10,000 of qualified wages for all calendar quarters). The Act increases the credit cap from $5,000 for the year to $7,000 (70% of $10,000) for any calendar quarter.[3] Accordingly, the Act will increase the maximum amount of credit available in 2021 for each employee from $5,000 to $28,000.
PPP borrowers may receive the tax credit. The CARES Act denied the employee retention tax credit to any employer that receives a loan under PPP, and defined the term “employer” expansively, potentially causing acquiring corporations with employee retention tax credits to lose or recapture those tax credits if they acquired a target company that had received a PPP loan.[4] The Act permits an employer that r ....

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Summary of Tax Provisions in Consolidated Appropriations Act

Tuesday, December 29, 2020
Expenses Related to PPP Loan Forgiveness Are Deductible. The CARES Act included a loan forgiveness program under the Small Business Administration’s Paycheck Protection Program (the “PPP”). A PPP loan may be forgiven if its proceeds are used for “payroll costs” or certain other expenses. Under the CARES Act, the forgiveness of a PPP loan does not give rise to taxable cancellation of indebted income, or a loss of tax attributes. However, the IRS held that expenses that gave rise to PPP loan forgiveness were not deductible.
[1] The Act reverses this rule and permits taxpayers whose PPP loans are forgiven to deduct the expenses relating to their loans to the extent they would otherwise qualify as ordinary and necessary business expenses. ....

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