Angelo Ciavarella

Angelo Ciavarella

Reed Smith

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Latest Publications


Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions – With Retroactive Effect!

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the circumstances under which related corporations (and, in some cases,...more

5/5/2016 - Bifurcation Capitalization Controlled Groups Corporate Counsel Debt Double Taxation Foreign Investment Income Taxes Proposed Regulation Publicly-Traded Companies Related Parties Required Documentation Stocks U.S. Treasury Withholding Tax

IRS Issues Guidance on Application Process for Tax Credits for Manufacturers of Renewable Energy Property

The American Recovery and Reinvestment Act of 2009 (the "Recovery Act") added a number of significant new tax incentives for businesses engaged in the renewable energy market, including a program that provides a tax credit to...more

3/13/2013 - American Recovery and Reinvestment Act DOE Manufacturers Renewable Energy Tax Incentives

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