The United States has tax treaties with nearly 70 countries to prevent double taxation and curb tax evasion. These treaties, based on Article II, Section 2 of the U.S. Constitution, are reciprocal and...
Real estate activities are highly regulated, and each state has laws governing specific prohibited practices as well as liabilities and penalties for violations. Explore this state law survey covering...
Contractual disputes regarding allegations of fraud are often complex, time-consuming, and expensive to litigate. Parties may amicably negotiate an acquisition agreement without even considering whether...
This practice note covers FDA prior notice requirements for imported food, including scope and exceptions, notification contents and timing, methods of submitting notice, and consequences for failing to...
Do you need guidance on drafting international employment contracts? Read our International Employment Agreements: Key Drafting Tips practice note, by John L. Sander, Michael Watts, and William Ellis,...
Recognizing the need for liquidity due to the economic effects of the COVID-19 pandemic, the IRS has provided temporary guidance on the treatment of certain stock distributions by publicly offered real estate investment trusts (REITs). Rev. Proc. 2021-53 modifies the safe harbor provided in earlier guidance by temporarily reducing the minimum required aggregate amount of cash that distributee shareholders may receive to not less than 10% of the total distribution, for such distribution to be treated as a distribution of property under I.R.C. § 301. REITs are tax-favored investment vehicles focused exclusively on real estate interests and offer their beneficial owners or shareholders certain tax advantages.
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