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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

Structured Finance Spectrum – February 2023

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features a new year for a new UCC Article 12, a farewell to LIBOR, and an appraisal...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

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

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

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

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

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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