News & Analysis as of

Interest Income Internal Revenue Code (IRC)

Cadwalader, Wickersham & Taft LLP

Tax Court Adopts Broad Reading of Profits Interests Safe Harbor

Thirty years after the IRS first acknowledged that taxpayers could receive profits interests for services without immediate tax, the Tax Court has confirmed our long-held belief that the same protection is available for a...more

Eversheds Sutherland (US) LLP

Florida District Court of Appeals hears oral arguments in addback dispute

​​​​​​​On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more

McDermott Will & Emery

Proposed New Code Sec. 163(n) and Removal of Expense Allocation to GILTI

This column describes new proposed Code Sec. 163(n) and the proposed general removal of expense allocation to GILTI in the Build Back Better Act (the “BBBA”). This column focuses on the version of the BBBA proposed on...more

Nutter McClennen & Fish LLP

Massachusetts May Refuse to Adopt Federal Interest Expense Limits

The Massachusetts House of Representatives overwhelmingly voted in favor of a bill to decouple the Massachusetts tax code from a significant federal interest deduction limitation. The federal limitation is contained in...more

Eversheds Sutherland (US) LLP

Proposed 163(j) regulations provide needed guidance to utilities

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Skadden, Arps, Slate, Meagher & Flom LLP

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Troutman Pepper

Tax Proposals to Eliminate Interest Deductions Miss the Mark

Troutman Pepper on

The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies. In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more

K&L Gates LLP

Recent Legislative Developments Will Create Headaches and Increase Financial Risks for Mortgage Servicers and Originators

K&L Gates LLP on

Two recent legislative developments, which have largely gone unnoticed, will dramatically raise the stakes for mortgage servicers and originators who file IRS Forms 1098. First, the Trade Preferences Extension Act of 2015,...more

K&L Gates LLP

New Nevada Commerce Tax Effective July 1, 2015

K&L Gates LLP on

While not purporting to give specific advice on Nevada tax law, the following is a summary of some of the general principals underlying the new tax law. A new Nevada Commerce Tax (“NCT”) was signed into law by Nevada Governor...more

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