Tax Benefits

News & Analysis as of

M&A Update: Treasury Announces Second Anti-Inversion Notice

On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more

Angola's New Private Investment Law

On 11 August 2015, Angola's New Private Investment Law ("NPIL") came into force on its publication in Angola's Gazette, repealing the previous 2011 law. Like its predecessor, the NPIL sets out the rules applicable to...more

US Supreme Court: Same-Sex Couples Have Constitutional Right to Marry

The gay rights movement saw decades of litigation and activism culminate in victory when the Supreme Court made the United States the 21st country to legalize same-sex marriage nationwide. Unlike its 2013 decision in United...more

Possible Regulatory Changes Could Reduce Tax Benefits of Transfers of Interests in Family-Owned Entities

Historically, the Internal Revenue Service has closely scrutinized transfers between family members of interests in family-owned entities. Among other actions, the Service has sought to curtail the use of discounts to...more

Tax Law Blog: Health Savings Accounts: Beneficiaries and Taxes

As high deductible health insurance plans become more prevalent, so do health savings accounts (HSAs). While most participants are aware of the tax implications of an HSA during life (contributions are deductible from gross...more

Should You Abandon An Underperforming Partnership?

Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more

Abandonment Losses Back on the Table!

Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

Obama Releases Tax Proposals for 2015

The proposed U.S. tax changes highlighted in President Obama’s State of the Union address on January 20 fall far short of the broad U.S. federal tax reform that members of Congress believe is needed for fundamental fairness...more

New Treasury Regulations Target Corporate Inversions

Last week, the Internal Revenue Service and Treasury Department announced a number of new regulations intended to make it more difficult to qualify for tax advantages associated with inversion transactions and reduce certain...more

Treasury Announces Inversion Regulations; Reach Extends to Other Cross-Border M&A

New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions. On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more

Treasury Takes Action Against Corporate Inversions

Earlier this week, the Treasury Department and the IRS announced that they would issue regulations that substantially limit the U.S. tax benefits of corporate inversions (and certain post-inversion transactions)....more

Summary of IC-DISC Tax Benefits

Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more

Captive Insurance: Feds Promote Tax Benefits, but Pay Attention to the Details

Recent IRS rulings and a U.S. Tax Court decision continue to lay a solid foundation for captive insurance companies. However, the tax requirements must be strictly followed. Below we provide an update to assist captives in...more

IRS Issues Guidance on Qualified Plan Amendments Regarding Same Sex Spouses

Employers have been considering the impact on benefit programs, including the qualified retirement plans, of the U.S. Supreme Court’s decision recognizing the validity of same sex marriages. In September, 2013, the IRS issued...more

IRS Guidance On Same-Gender Marriage - What Actions Should Plan Sponsors Take Now

Following the Supreme Court’s decision in United States v. Windsor, the IRS announced in Revenue Ruling 2013-17 that lawfully married same-sex couples would be treated as married for all Internal Revenue Code purposes. On...more

Treasury Department Issues Guidance on Application of Same-Sex Marriage Ruling to Retirement Plans

On April 4, 2014, the Department of the Treasury issued its long-awaited supplemental guidance on when and how tax-qualified retirement plans (including 401(k) plans) must comply with Windsor v. United States, in which the...more

Senate Finance Committee Passes Bill to Extend Certain Lapsed Tax Breaks

The Senate Finance Committee passed the Expiring Provisions Improvement Reform and Efficiency Act (EXPIRE Act) on April 3, 2014. The legislation would renew through 2015 more than 50 tax incentives that either have lapsed or...more

IRS Announces Deadline to Amend Retirement Plans for Same-Sex Benefits

On April 4, 2014, the Internal Revenue Service (the “Service”) published Notice 2014-19, in which it describes amendments required to be made to retirement plans qualified under Section 401(a) of the Internal Revenue Code of...more

The Honeymoon Is Over: IRS Says It Is Time to Amend Plans to Cover Same-Sex Spouses

On April 4, 2014, the Internal Revenue Service (IRS) released Notice 2014-19, which provides a series of Q&As regarding the application of the U.S. Supreme Court’s decision in United States v. Windsor and the IRS’s prior...more

Tax Implications for Same-Sex Married Couples Residing in The Carolinas

As the April 15th filing deadline approaches, there are important changes to note. When the U.S. Supreme Court struck down the Defense of Marriage Act (DOMA) on June 26, 2013, a number of important tax issues were raised...more

“New Jobs For New Jersey Act” Would Provide Tax Benefits To Smaller Private Employers Hiring Unemployed Workers

On January 6, 2014, the Senate introduced a bill (S153) that would provide incentives to small private sector employers that increase their workforce by hiring unemployed workers. Under the legislation, employers with 100 or...more

Domestic Anti-Treaty-Shopping Proposals and Further Consultation Announced in Canada's Federal Budget 2014

In the Canadian Federal Budget released on February 11, 2014, the Department of Finance signaled its intention to enact a domestic treaty-shopping rule, generally allowing the Canada Revenue Agency (CRA) to deny treaty...more

New Tax Benefits for Investment Projects in the Russian Far East

Companies that carry out qualifying investment projects in the Russian Far East enjoy tax benefits under a new Federal Law “On the Introduction of Amendments to Parts One and Two of the Tax Code of the Russian Federation...more

Pledge Of LLC Interest Enough For Avoiding Income On Indebtedness Discharge

Code §108(a)(1)(D) avoids debt discharge income to taxpayers (other than C corporations) when indebtedness is forgiven if it is qualified real property business indebtedness. This is generally indebtedness incurred in...more

An Overview of The Up-C Structure in Energy Deals

The UP-C structure — which offers tax benefits to pre-IPO investors and sponsors — likely will expand among energy companies. In 2013, several energy companies went public using a so-called UP-C structure. In using...more

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