On September 27, 2017, a group of top Trump administration officials and key leaders from the House and Senate released an aspirational outline for future tax reform referred to as the “Unified Framework” (the “Framework”). ...more
On January 29, 2014, the Internal Revenue Service (“IRS”) and the Treasury Department issued proposed regulations (the “Proposed Regulations”) modifying the rules under Section 752 regarding the allocation of recourse and...more