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Capital Markets Tax Quarterly

23 January 2019

Volume 1, Issue 2

Mayer Brown’s Capital Markets Tax Quarterly, provides capital markets-related US federal tax news and insights. In this volume of CMTQ, we look at Q4 2018.

In this issue, we discuss:

  • Proposed BEAT Regulations: Exception for Internal TLAC
  • Mutual Funds That Hold REIT Shares – Are the Fund Dividends Eligible for the 20% Code Section 199A Deduction?
  • Proposed FATCA Regulations: Gross Proceeds Is Gone!
  • Proposed Regulations Implementing Section 163(j) and the Anti-Hybrid Rules
  • Proposed Regulations on Section 956’s “Deemed Dividend” Rules for US Corporate Shareholders
  • PLR 201844003: REIT’s Sale of Property Pursuant to a Plan of Liquidation Not a Prohibited Transaction
  • Reminder of Upcoming FATCA and QI Certifications
  • IRC Section 1400Z Qualified Opportunity Zones: Executive Order Establishing the White House Opportunity and Revitalization Council
  • Split in the Circuits on Determining FBAR Willful Violation Penalty Cap