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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 17, 2022 – October 21, 2022...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 30, 2020 – December 4, 2020... November 30, 2020: After releasing a pre-publication...more
The U.S. Department of the Treasury (Treasury) issued proposed regulations (the Proposed Regulations) on April 8, 2020, that would restrict foreign persons' ability to minimize U.S. tax through "conduit" financing...more
The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 25 – May 29, 2020... May 26, 2020: The IRS and United States Department of the Treasury...more
The Internal Revenue Service (IRS) released proposed regulations amending Employment Tax Regulations (26 CFR Parts 31 and 35) under section 3405 of the Internal Revenue Code (IRC). The regulations propose new rules for...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10 – 14, 2020. February 10, 2020: The IRS issued a revenue ruling providing guidance...more
In 2019, we published analysis to help tech and life sciences companies navigate U.S. tax law changes, an evolving IP landscape and new privacy regulations such as the California Consumer Privacy Act. We also tracked venture...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22–26, 2019. July 22, 2019: The IRS issued a revenue procedure in which it issued indexing...more
Our International Tax Group takes stock of new proposed regulations that expand withholding on foreign partners transferring interests in partnerships doing business in the U.S. and tighten the reins on exceptions....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27 – May 31, 2019. May 28, 2019: The IRS released Announcement 2019-05 listing recent...more
Proposed regulations have recently been issued by the U.S. Internal Revenue Services (IRS) under a withholding provision of U.S. tax law enacted in 2017 that imposes withholding tax on a non-U.S. person’s sale (or other...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 14 – 18, 2019. January 15, 2019: The IRS issued final regulations implementing the...more
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. ...more
By release of Notice 2018-97, the IRS provided initial guidance on the application of new Section 83(i) of the Internal Revenue Code, as enacted by the Tax Cuts and Jobs Act (2017). Additional guidance is expected in the...more
The IRS has proposed new regulations that would amend the definition of a “registration-required obligation” to broaden the scope of the types of arrangements that constitute pass-through certificates that generate portfolio...more
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
BROKER-DEALER - FINRA Requests Comment on Revised Price Disclosure Information Standards for Corporate and Agency Debt Securities - The Financial Industry Regulatory Authority issued a regulatory notice...more