Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more
10/29/2019
/ Alternative Reference Rates Committee (ARRC) ,
Exemptions ,
Fair Market Value ,
Financial Instruments ,
Interest Rates ,
IRS ,
ISDA ,
Libor ,
Popular ,
Proposed Regulation ,
Public Finance ,
Regulatory Agenda ,
Rulemaking Process ,
Safe Harbors ,
Secured Overnight Funding Rate (SOFR) ,
Swaps ,
Tax Exemptions ,
Tax Planning ,
Tax Relief
The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010.
The Irish company Google Ireland Limited sells digital...more
9/12/2017
/ BEPS ,
Corporate Taxes ,
Double Taxation ,
France ,
Google ,
Income Taxes ,
Ireland ,
Multilateral Agreement ,
OECD ,
Tax Treaty ,
Value-Added Tax (VAT) ,
Withholding Tax
New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon. This outline describes the new issue price rules, provides a high-level strategic analysis to help guide a...more
The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more
On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime (the "Act"), most notably for out-of-state corporations providing digital products to New...more
On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more