On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more
Over the past several months, there has been much speculation regarding potential changes to corporate and individual tax rates. The infrastructure plan released by the White House on Wednesday, March 31, includes a proposed...more
Background -
On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more
9/28/2020
/ Business Taxes ,
CARES Act ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Legitimate Business Interest ,
Regulatory Requirements ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more
Transaction expenses, including fees for legal counsel, accountants, financial advisors, brokers and other third parties, are an ineluctable aspect of mergers and acquisitions. The ability of parties to deduct at least a...more
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more
Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more
11/16/2018
/ Collateral ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Foreign Subsidiaries ,
Internal Revenue Code (IRC) ,
IRS ,
Lenders ,
Parent Corporation ,
Proposed Regulation ,
Section 956 ,
Tax Deductions ,
Tax Planning ,
Voting Securities
The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more
3/29/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
The tax reform signed into law by President Trump on Dec. 22 (the Tax Act) presents public companies with several accounting and disclosure challenges. Although companies are still evaluating how they will be affected by the...more
1/2/2018
/ Corporate Taxes ,
Disclosure Requirements ,
Financial Statements ,
Form 8-K ,
Income Taxes ,
New Legislation ,
Publicly-Traded Companies ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more
1/2/2018
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Compensation & Benefits ,
Corporate Taxes ,
Executive Compensation ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Section 162(m) ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On Dec. 20, 2017, the House of Representatives by a vote of 224 to 201 passed the most significant tax legislation in more than three decades. The Senate passed the same legislation earlier in the day....more
On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act. The Senate Budget Committee voted on Nov. 28, 2017, to send the Senate version of the bill to the floor,...more
12/4/2017
/ Alternative Minimum Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration