Our Tax Group reviews how the U.S. Supreme Court’s ruling in Loper Bright that overturned many decades of the Chevron doctrine will affect federal and state taxes....more
Our Tax Group sheds light on recent IRS rulings that disallow deductions involving success-based fees in M&A transactions. Contrary to common practice, the IRS recently ruled target companies could not deduct success-based...more
It is said the future is not yet written. But the Biden Administration has a draft ready for Congress. Our Federal Tax Group gazes into the Made in America tax plan to find the many questions that await within....more
Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes....more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more
LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more
9/2/2015
/ Business Assets ,
Capital Gains ,
Commercial Real Estate Market ,
Cross-Border Transactions ,
Foreign Affiliates ,
Goodwill ,
Intangible Property ,
Real Estate Investments ,
Related Parties ,
Section 1031 Exchange ,
Tax Planning