Martine Seiden Agatston
Martine Seiden Agatston 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
On May 4, 2020, the IRS issued Revenue Procedure 2020-19, which temporarily allows a publicly-offered REIT or RIC to pay as much as 90% of a distribution in its own stock (rather than cash or other property) and still have the entire amount treated as a dividend for US federal income tax purposes. As a … Continue Reading
This blog post summarizes some of the tax considerations for REITs that have arisen in light of COVID-19, the resulting economic downturn, the Coronavirus Aid, Relief, and Economic Securities (“CARES”) Act, and the Families First Coronavirus Response Act (the “FFCRA”).… Continue Reading
On December 4, 2018, FinCEN issued Notice 2018-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2020. FinCEN has provided similar extensions over the previous … Continue Reading
On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”), which provides that a repatriation deemed to have been received by a registered investment company (a “RIC”) under Section 965 (enacted as part of the 2017 tax reform act, commonly known as the “Tax Cuts and Jobs Act” or … Continue Reading
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in cross-border transactions, and this post describes them in general terms without all of their fine details. The discussion of foreign … Continue Reading
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will affect every US taxpayer, including participants in the capital markets. The purpose of … Continue Reading
On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online.[1] These additional FAQs clarify recent temporary regulations (the “Temporary Regulations”) requiring that a beneficial owner withholding certificate contain a foreign taxpayer identification number (“TIN”) and, … Continue Reading
The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”)[1] reducing from ten years to five years the recognition period for the corporate-level tax imposed on certain property dispositions by a real estate investment trust (“REIT”) or a regulated investment company (“RIC”) under Section 337(d), and … Continue Reading
As noted in our January 5, 2017 client alert, FinCEN issued Notice 2016-1, which extends the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2018. Please click … 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
New Guidance Allows Publicly-Offered REITs and RICs to Issue up to 90% of Qualifying Dividends in the REIT or RIC’s Own Stock Through the End of the Year.
By David S. Miller, Martin T. Hamilton and Martine Seiden Agatston on Posted in Coronavirus, REITs, RIC (BDCs)
Covid-19: Tax Considerations for REITs
By David S. Miller and Martine Seiden Agatston on Posted in Coronavirus, REITs
Extension of FBAR Filing Deadline for Certain Filers
By Abraham Gutwein, Amanda H. Nussbaum, David S. Miller, Michael Fernhoff and Martine Seiden Agatston on Posted in International Taxation
New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs
By Martin T. Hamilton, Martine Seiden Agatston and Timothy Donovan on Posted in Corporate Taxation, GILTI, International Taxation, REITs, RIC (BDCs), Tax Cuts and Jobs Act, Tax Reform
Impact of Recent Tax Legislation on M&A Transactions
By Martine Seiden Agatston, Malcolm Hochenberg, Martin T. Hamilton, Kathleen R Semanski, Amy Zelcer, Alan Parnes, Amanda H. Nussbaum, Abraham Gutwein and Richard M. Corn on Posted in Corporate Taxation, Cost Recovery, In the news, International Taxation, Mergers & Acquisitions, Partnership Taxation, Tax Reform
New Tax Law (H.R. 1): Key Highlights Related to Interest Bearing Debt
IRS Updates FATCA FAQs, Addresses January Temporary Regulations
IRS Issues Final Regulations on REIT and RIC Conversion Transactions
By Martin T. Hamilton, Martine Seiden Agatston and Timothy Donovan on Posted in Real Estate, REITs
Extension of FBAR Filing Deadline for Certain Filers
By Amy Drais, Abraham Gutwein, Amanda H. Nussbaum and Martine Seiden Agatston on Posted in International Taxation
