On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more
On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more
On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more
On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more
4/10/2018
/ Carried Interest Tax Rates ,
Charitable Trusts ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Local Taxes ,
Payroll Taxes ,
Proposed Legislation ,
State Budgets ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Transition Tax ,
Trust Funds
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
Reorganizations ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions
On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more
10/10/2016
/ Capital Gains ,
Debt Instruments ,
Disguised Sales ,
Internal Revenue Code (IRC) ,
Joint Venture ,
Master Limited Partnerships ,
Non-Recourse Loans ,
Partnership Liabilities ,
Partnerships ,
Publicly-Traded Companies ,
REIT ,
Tax Allocation Agreements ,
Tax Liability ,
Tax-Deferred Exchanges