This report argues that traditional REIT spinoffs are fairly well supported by current law and that the common criticisms of these transactions generally miss the mark. It concludes that (1) Treasury and the IRS over time have adopted a fairly comprehensive definition of real property for REIT...

Securities crowdfunding — the sale of unregistered securities to the public over the Internet — has come under attack before it has even begun. Legal scholars in particular have expressed concern that investors will lose any money they invest in crowdfunding companies. Even assuming that...

In 2011 the Department of Treasury issued regulations that, for the first time, empowered the IRS to regulate the practice of preparing tax returns. Naturally, many tax return preparers were not happy about being regulated by the Feds. In 2013 a federal district judge nuked the regulations,...

This article analyses the meaning of the definitions of dividend and interest in the OECD Model by reference to their historical evolution. In the dividend definition the origin of 'other corporate rights' is traced to a 1958 OEEC Working Party minute in which the same French expression used in...