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ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

ASKramer Law on

When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

ASKramer Law on

What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

ASKramer Law

Business Taxation of Hedging Transactions Part I: Hedging Risks

ASKramer Law on

Enterprise Risk Management is widely used in many industries and businesses. Risk managers use increasingly sophisticated approaches, methods, analytics, and frameworks to manage complex, interrelated, and interconnected...more

Walkers

Budget 2024 – Tax Highlights Ireland

Walkers on

10 October 2023 – Ireland's Budget 2024 was presented in the context of a positive economic performance for Ireland — full employment, budget surpluses, rising population and a falling national debt — against a backdrop of...more

McDermott Will & Emery

Weekly IRS Roundup June 5 – June 9, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Emery

Weekly IRS Roundup January 28 – February 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 28 – February 1, 2019. January 28, 2019: The IRS issued Revenue Ruling 2019-04,...more

McDermott Will & Emery

The Impact of Tax Reform on Finance

Two key changes to business tax provisions in the Tax Cuts and Job act that will interest private equity sponsors and their lenders are the new limitation on deductibility of business interest expense and the temporary...more

Sheppard Mullin Richter & Hampton LLP

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

McDermott Will & Emery

UK Government Confirms Introduction of New Cap on Interest Deductibility

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The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more

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