On December 20, 2017, the Senate and House of Representatives passed H.R. 1, known as the “Tax Cuts and Jobs Act” (“Tax Reform Bill”). President Trump is expected to sign the Tax Reform Bill by early January. The Tax Reform...more
12/21/2017
/ Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Pending Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more
12/13/2017
/ BEPS ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Popular ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 14, 2017, Senate Finance Committee Chairman, Orrin Hatch (R-Utah), released his modified tax reform plan (“Senate Bill”), which adopts some of the House Bill proposals (as amended) (“House Bill”), but also...more
11/20/2017
/ Carried Interest ,
Corporate Taxes ,
EBITDA ,
Excise Tax ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Partnership Interests ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more
11/9/2017
/ Collateralized Loan Obligations ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Legislative Agendas ,
Legitimate Business Interest ,
Pass-Through Entities ,
Securitization Vehicles ,
Tax Code ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
UBTI
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”) which includes significant changes to the current U.S. federal income tax regime for businesses and...more
11/6/2017
/ Business Taxes ,
Corporate Counsel ,
Corporate Taxes ,
Excise Tax ,
Insurance Industry ,
International Tax Issues ,
Like Kind Exchanges ,
Net Operating Losses ,
Partnerships ,
Related Parties ,
S-Corporation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness...more
On April 4, 2016, Treasury released new rules making it more difficult for some U.S. companies to invert (“Serial Inversion Regulations”), Proposed Regulations limiting the effectiveness of “earnings stripping” techniques...more
Corporate inversions have constituted an active and successful part of the M&A market in 2013 and early 2014, as acquirors have typically traded up on the date of announcement. However, there is now a new urgency for U.S....more