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IRS Signals Increased Scrutiny of Deductibility of Success-Based Fees in M&A Transactions

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

YA Global, the Existence of a U.S. Trade or Business, and the Search for Greater Clarity

Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more

PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions

The potential complexities surrounding pass-through entity tax elections might make you cry, but the potential tax benefits won’t make you blue. Our Federal Tax Group examines how PTET elections have become an important...more

Crypto Asset Industry Cautious as Biden Administration Proposes New Reporting Rules

Our Federal Tax Group mines recent legislative proposals for amendments that could change the way crypto assets are reported – and taxed. Proposed amendments to Section 6045 - The status of mining and staking activities...more

Check Your Timing: Tax Traps for the Unwary in Acquisition Agreements

Even one day of unanticipated tax liabilities can have meaningful consequences. Our Federal Tax Group turns your attention to the little-regarded – but still important – straddle-period provisions in acquisition agreements....more

IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions

The CARES Act’s Paycheck Protection Program (PPP) was a boon to many businesses, but some of its particularities have become a headache to acquiring taxpayers. Our Federal Tax Group untangles how PPP loans affect employee...more

Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies

Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums....more

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed...more

5/19/2020  /  CARES Act , IRS , Tax Cuts and Jobs Act

IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts

Our Federal Tax Group discusses a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related...more

4/16/2020  /  Coronavirus/COVID-19 , IRS , REMIC , Trusts

IRS Provides Partnerships a Mechanism to Claim Benefit of Retroactive CARES Act Provisions

Our Federal Tax Group explains new IRS relief that permits partnerships to file amended returns for their 2018 and 2019 taxable years to claim the benefit of retroactive provisions in the Coronavirus Aid, Relief, and Economic...more

4/10/2020  /  CARES Act , IRS , Revenue Procedures

Finally! Final Regulations Published for Section 965 Transition Tax

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

The Tax Act’s New Business Interest Expense Limitation – Dear IRS: Some Guidance, Please?

The Tax Cuts and Jobs Act replaced the earnings stripping rules with a new limitation on deductions for business interest expense. Our International Tax Group examines the new law and what it means for interest expense...more

Treasury Would Overhaul 2016 Regulatory Guidance

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

Information Exchange Under the OECD’s Common Reporting Standard Begins Early in Select Countries

Modeled after the Foreign Account Tax Compliance Act (FATCA) – the U.S.’s information reporting regime for U.S. holders of foreign accounts – the Organisation for Economic Co-Operation and Development (OECD) approved the...more

Trump’s Tax Reform Plan – When the Dessert Pays for Dinner

Doubling down on his promise to achieve monumental tax reform, President Trump on April 26 issued a tax reform plan outlining his Administration’s broad aims. Once again, he has made it clear that large-scale tax reform is a...more

The PFIC Regulations Get a Facelift

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

Investment Management, Trading & Markets Advisory: Annual CPO or CTA Exemption or Exclusion Affirmations Due by February 29, 2016;...

Any firm that is currently claiming certain exemptions or exclusions from registration with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator (CPO) or commodity trading advisor (CTA) is required to...more

A Reverse Morris Trust Ruling

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

Unusual Like-Kind Exchanges

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

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