H. Karl Zeswitz, Jr.

H. Karl Zeswitz, Jr.

Sutherland Asbill & Brennan LLP

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Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

3/6/2014 - Capital Gains Corporate Tax Rates Corporate Taxes Employee Benefits Energy Executive Compensation Foreign Nationals Income Taxes Insurance Companies Net Investment Income Partnerships Real Estate Market REIT RICs S-Corporation Tax Credits Tax Deductions Tax Reform Tax Returns

A New Way to Unwind (Leveraged Partnership Structures): Treasury and IRS Propose Draconian Changes to the Partnership Liability...

On January 29, Treasury and the IRS issued proposed regulations that would dramatically change the manner in which partnership liabilities are allocated among the partnership’s partners under IRC § 752 (the Proposed...more

2/5/2014 - IRS Partnerships U.S. Treasury

DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule and Offer a Few Other Surprises

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of Section 7874(c)(2)(B) to...more

1/23/2014 - De Minimus Quantity Exemption Internal Revenue Code Inversion IRS Public Offerings Stocks U.S. Treasury

New Final Regs on Use of Differential Income Stream in Evaluating Cost-Sharing Arrangements

On August 26, 2013, the United States Treasury Department issued new final regulations under Internal Revenue Code (IRC) Section 482. The new regulations provide guidance on the “income method” for determining taxable income...more

9/3/2013 - Cost-Sharing IRC Licensing Rules New Regulations U.S. Treasury

Legal Alert: Not Exactly a Day in the Sun: U.S. Court of Appeals Holds Private Equity Fund Is Engaged in a Trade or Business

In Sun Capital Partners III LP v. New England Teamsters & Trucking Industry Pension Fund, No. 12-2312, 2013 WL 3814984 (1st Cir. July 24, 2013), the U.S. Court of Appeals for the First Circuit effectively found that the...more

8/1/2013 - ERISA Fund Managers Investment Funds Pensions Pooled Investment Vehicles Private Equity Private Equity Funds Sun Capital Partners

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

7/16/2013 - Deadlines Delays FATCA FFI Foreign Jurisdictions IGAs Internal Revenue Code IRS U.S. Treasury

Legal Alert: The End of an Era: IRS Expands “No-Rule” Policy for Spin-Offs and Other Common Corporate Transactions

On June 25, the IRS expanded its “no-rule” policy with respect to spin-offs and other tax-free corporate separations, liquidations, contributions, and reorganizations. Effective for letter ruling requests received by the IRS...more

6/27/2013 - Integrated Transactions IRS Liquidation No-Rule Policy Spinoffs

At Last: Final Regulations Issued Under Section 336(e)

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more

5/14/2013 - Corporate Taxes Distribution Rules IRS Proposed Regulation Stocks

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