Christine N. Younger
Christine Sherman is an associate in the Tax Department.
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On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section 199A[1] to regulated investment companies (“RICs”) that receive dividends from real estate investment trusts (“REITs”). The Final Regulations broadly allow a “conduit” approach, … Continue Reading
The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the Proposed Regulations”) released on October 9, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) addressed market … Continue Reading
On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, “Kaestner”).[1] In a unanimous opinion delivered by Justice Sotomayor, the Court held that under the Fourteenth Amendment’s Due Process Clause,[2] a state may not tax trust income based solely on the in-state residency … Continue Reading
On June 7, 2019, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed Treasury regulations under Sections 897, 1445 and 1446 (the “Proposed Regulations”) regarding the exception for qualified foreign pension funds (“QFPFs”) from taxation under the Foreign Investment in Real Property Tax Act (“FIRPTA”) provisions of the Internal Revenue Code … Continue Reading
On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for players, coaches and managers) and draft picks as having a zero value for determining gain or loss recognized for federal income tax purposes … Continue Reading
“Passthrough Deduction” Regulations for RICs Finalized with No Major Changes
By Stuart Rosow, Martine Seiden Agatston, Malcolm Hochenberg, Martin T. Hamilton, Christine N. Younger, Amanda H. Nussbaum and Richard M. Corn on Posted in IRS, REITs, RIC (BDCs), Section 199A, Tax Cuts and Jobs Act
LIBOR Transition: U.S. Tax Guidance From the IRS
By Christine N. Younger, Martin T. Hamilton, Malcolm Hochenberg and Stuart Rosow on Posted in financial products, In the news, IRS
State Tax on Trust Income Based Solely on In-State Residence of Beneficiaries Found Unconstitutional
By Richard M. Corn, Christine N. Younger, David S. Miller, Mitchell Gaswirth and Stuart Rosow on Posted in In the news, IRS, Notable Decisions, State Taxation
Proposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception
By Timothy Donovan, Martin T. Hamilton, David S. Miller, Christine N. Younger and Amanda H. Nussbaum on Posted in FIRPTA, International Taxation, IRS, Real Estate, REITs, U.S. Inbound Real Estate Investment, Withholding and FATCA
Players, Staff and Draft Picks May be Traded Tax-Free Under New Safe Harbor
By Richard M. Corn, Amanda H. Nussbaum, Alan Parnes, Christine N. Younger, Jon Oram and Malcolm Hochenberg on Posted in IRS, Tax Cuts and Jobs Act, Tax Reform
