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The All Cash D Is Dead – Long Live the All Cash D

Tax Reform and All Cash D Reorganizations - With the introduction of global intangible low-taxed income (GILTI) as a new category of income of controlled foreign corporations (CFCs) currently taxable in the United States...more

Section 163(j) Interest Expense Limitation

The newly enacted version of section 163(j) limits deductions for business interest expense. Although the prior version of section 163(j) applied almost exclusively to US corporations with non-US parents, the new version of...more

US Tax Reform Measures Affecting Foreign Multinationals

On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more

The Impact of Tax Reform on Private Equity and M&A Transactions

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

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