Lisa Watts

Lisa Watts

Latham & Watkins LLP

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Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

4/21/2016 - Acquisitions Anti-Inversion Regulations Controlled Foreign Corporations Controlled Groups Corporate Taxes De Minimus Quantity Exemption Dividends Foreign Corporations Inversion IRS Multinationals Proposed Regulation Related Parties Stocks U.S. Treasury

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

4/21/2016 - Affiliates Anti-Avoidance Consolidated Tax Returns Controlled Groups Cross-Border Transactions Debt Dividends Foreign Corporations Income Taxes IRS Proposed Regulation REIT Related Parties Required Documentation Stocks U.S. Treasury Withholding Tax

IRS Proposes Significant Changes to Rules for Allocating Partnership Liabilities

Proposed Regulations seek to curtail perceived abuses, including the use of “bottom-dollar” guarantees and some indemnity arrangements. On January 29, 2014, the Internal Revenue Service (IRS) proposed regulations that...more

2/10/2014 - Indemnification IRS Partnerships Tax Liability

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