McDermott Will & Emery’s Family Office Tax Roundtable provides participants with an interactive virtual program focused on select income and transfer tax considerations for family enterprises. Attendees will hear...more
10/20/2020
/ Acquisitions ,
Family Offices ,
Income Taxes ,
Mergers ,
New Regulations ,
Partnerships ,
S-Corporation ,
Tax Planning ,
Tax Reform ,
Transfer Taxes ,
U.S. Treasury ,
Webinars
The CARES Act allows individuals, estates and taxable trusts with certain business losses in 2018, 2019 and 2020, including losses from pass-through entities, to obtain refunds of taxes paid in the prior five years...more
The CARES Act mid-size and large business loan program dividend restriction is written as if all eligible businesses have common stock and may pay dividends. Pass-through entities that obtain CARES Act loans from the mid-size...more
4/1/2020
/ Business Closures ,
Business Interruption ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
Financial Stimulus ,
Lenders ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Relief
The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The...more
Now that the 2017 tax reform act is law, private equity and M&A professionals must grapple with its sweeping changes and reconcile the new provisions with how they do business. This On the Subject summarizes important...more
1/3/2018
/ Acquisitions ,
Alternative Minimum Tax ,
Business Income ,
C-Corporation ,
Capital Expenditures ,
Corporate Taxes ,
EBITDA ,
International Tax Issues ,
IRS ,
Mergers ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Qualified Small Business Stock ,
S-Corporation ,
Tax Rates ,
Tax Reform ,
Trump Administration
Impact of Country-By-Country Reporting on Multinational Enterprises -
Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more
4/21/2017
/ Audits ,
BEPS ,
Bipartisan Budget Act ,
Border Adjustment Taxes ,
Country-by-Country ,
International Tax Issues ,
Multinationals ,
OECD ,
Proposed Regulation ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
U.S. Treasury ,
Underpayment
Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders -
Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more
2/1/2016
/ Audits ,
Bipartisan Budget ,
FIRPTA ,
Holding Companies ,
International Tax Issues ,
Italy ,
Limited Liability Company (LLC) ,
Multinationals ,
OECD ,
Partnership Agreements ,
Protecting Americans from Tax Hikes (PATH) Act ,
REIT ,
Tax Extenders ,
Tax Extensions ,
The Patent Box ,
UK
On November 2, 2015, President Barack Obama signed the Bipartisan Budget Act of 2015 (the Act) into law, instituting for tax years commencing after 2017 significant changes to the rules governing federal tax audits of...more
In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more