Be diligent about the impact of loan modifications and foreclosures during the coronavirus pandemic. The passage of the Tax Cuts and Jobs Act led to an increase in the number of private lending funds converting to mortgage REITs over the past two years. Fund managers made the conversion decision by carefully weighing whether the tax […]
Reminders for REITs on Prohibited Transactions Read More »
The fund structure, accounting methods and other strategies must be considered in addition to securities compliance. A nonperforming loan (NPL) is a type of note that is in default, distressed, delinquent or otherwise dilapidated. NPLs are interchangeably used with nonperforming notes, distressed debts or distressed loans. Generally, an NPL holder no longer anticipates repayment from
Designing Nonperforming Note Funds Read More »
Fund managers may not be aware of their new role during an IRS audit of companies with partnered members. The new centralized partnership audit regime (CPAR) introduced by the Bipartisan Budget Act (BBA) started with the 2018 tax year. Under the old rules, there was no mechanism for the IRS to collect tax at the
What You Need to Know About the Centralized Partnership Audit Regime Read More »
