News & Analysis as of

U.S. Treasury Required Documentation

Paul Hastings LLP

Treasury Issues Additional Guidance on Low-Income Community Bonus Credit

Paul Hastings LLP on

On June 1, 2023, the Treasury Department (“Treasury”) issued a notice of proposed rulemaking including proposed rules (the “Proposed Rules”) regarding the “Low-Income Communities Bonus Credit Program” established by the...more

Epstein Becker & Green

Podcast: What's New for Insurers in Mental Health Parity Compliance - Diagnosing Health Care

Epstein Becker & Green on

The Departments of Labor, Health and Human Services, and the Treasury jointly released a set of frequently asked questions (“FAQs”) related to recent changes made to the Mental Health Parity and Addiction Equity Act effective...more

Fenwick & West LLP

The FDII Final Regulations Are Here: An Executive Summary and Observations

Fenwick & West LLP on

Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

McDermott Will & Emery

Burdensome Documentation Requirements Modified under the Final Section 250 Regulations

McDermott Will & Emery on

The US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have issued highly anticipated guidance (the Final Regulations) regarding the substantiation requirements necessary to claim a section 250...more

Hinshaw & Culbertson LLP

SBA and Treasury Provide PPP Loan Forgiveness Applications

Last month, the U.S. Treasury and the Small Business Administration (SBA) released two Paycheck Protection Program (PPP) loan forgiveness applications. The first was a new EZ PPP loan forgiveness application with instructions...more

Schwabe, Williamson & Wyatt PC

What to Know for Businesses Completing the PPP Loan Forgiveness Application - Update

On May 18, 2020, and May 26, 2020, Schwabe published two articles about the Paycheck Protection Program (“PPP”) Loan Forgiveness Application dated May 2020. On June 16, 2020, in light of the changes from the Paycheck...more

Foster Garvey PC

Let the Good Times Roll – The SBA Issues Interim Final Rules on PPP Loan Forgiveness, Including Guidance on the Payment of Bonuses...

Foster Garvey PC on

On Friday, May 22, 2020, the Small Business Administration (“SBA”), in conjunction and consultation with the U.S. Department of the Treasury (“Treasury”), published an interim final rule (“IFR”) containing new guidance on the...more

A&O Shearman

Section 385 Treasury Regulations Developments

A&O Shearman on

Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

Butler Snow LLP

Treasury Proposes Removal of Certain Section 385 Regulations

Butler Snow LLP on

On Friday, September 21, 2018, the Treasury Department issued proposed regulations removing the portion of the final Section 385 regulations dealing with the documentation requirements that must be satisfied for related-party...more

Cadwalader, Wickersham & Taft LLP

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Baker Donelson

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

Baker Donelson on

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

Foley & Lardner LLP on

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Eversheds Sutherland (US) LLP

Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes

On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations) that are intended to combat perceived concerns associated with indebtedness between...more

Dechert LLP

Significant Changes Made in Final FATCA Regulations

Dechert LLP on

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

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