Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Regulated Investment Company (RIC)

Final regs clarify controlled group rules for RIC asset diversification test

Final regs clarify controlled group rules for RIC asset diversification test

T.D. 9737, 09/14/2015, Reg. § 1.851-3, Reg. § 1.851-5 IRS has issued final regs that clarify how the controlled group rules apply for purposes of the regulated investment company (RIC) asset diversification test. The final regs adopt the provisions of the proposed regs with certain clarifications. Background. To qualify as a RIC, a taxpayer must meet […]

Read the full article →

Rev Proc sets out when RICs that invest in other RICs satisfy 25% asset diversification test

Rev Proc sets out when RICs that invest in other RICs satisfy 25% asset diversification test

Rev Proc 2015-45, 2015-39 IRB In a Revenue Procedure issued contemporaneously with final regs on controlled groups and the regulated investment company (RIC) asset diversification test, IRS has described the conditions under which it will treat a RIC that invests in one or more other RICs as satisfying Code Sec. 851(b)(3)(B)’s 25% asset diversification requirements, […]

Read the full article →

IRS guidance on RIC capital gains/losses includes mandatory RIC reporting requirement

IRS guidance on RIC capital gains/losses includes mandatory RIC reporting requirement

Notice 2015-41, 2015-24 IRB In a Notice, IRS has provided several new rules with respect to regulated investment company (RIC) capital gains and capital losses. Under one such rule, what had been an elective rule under which RICs could separately report different categories of capital gains (e.g., 20% capital gains vs. 28% capital gains) is […]

Read the full article →

Proposed regs clarify controlled group rules for RIC asset diversification test

Proposed regs clarify controlled group rules for RIC asset diversification test

IRS has issued proposed regs – Prop Reg § 1.851-5 – that would clarify how the controlled group rules apply for purposes of the regulated investment company (RIC) asset diversification test. Specifically, the proposed regs would make revisions to examples and add a new example to clarify that two corporations can constitute a controlled group […]

Read the full article →

Final regs except certain C corporation transfers to RICs and REITs from gain recognition

Final regs except certain C corporation transfers to RICs and REITs from gain recognition

 IRS has issued final regs T.D. 9626, Reg. § 1.337(d)-7, under Code Sec. 337(d) that except certain transfers of property from a C corporationto a regulated investment company (RIC) or a real estate investment trust (REIT) from gain recognition. The final regs apply to such transactions occurring on or after Aug. 2, 2013, but taxpayers […]

Read the full article →
Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney