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