Bill on Bankruptcy: Detroit Judge Might Lose Grip on the Case
A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more
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
Last December we told you about favorable IRS guidance letting P3 contractors and investors keep full tax deductions for interest on debt. The IRS kept a P3-friendly approach in last week’s proposed regulations on “qualified...more
Contractors and investors in P3s can continue taking a full tax deduction for interest on debt under recent IRS guidance (Revenue Procedure 2018-59, issued November 26). ...more
The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations. Key Points: ..The 30% Cap (as defined below) will apply at the consolidated group...more
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
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
The Impact of The EU General Data Protection Regulation - The EU General Data Protection Regulation 2016/679 (GDPR) was published in the Official Journal of the European Union on 4 May 2016 following the compromise...more
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