Archive - December 2012
Net Investment Tax Proposed Regs are Out!
I am a bit late to the party since the regulations actually came out a few days ago, but nonetheless, I wanted to share my first impressions. These have been long awaited by the community and they do not disappoint. One hundred and fifty nine pages, including the preamble, but I am not going to belabor the point of complexity and volume; I have been ruminating complexity enough on this blog. Per my preliminary review, the proposed regulations cover many of the points that the community expected them to cover, e.g. issues related to attribution of manager’s business, CFC/PFIC issues,...
December 11, 2012 read more