Surprisingly, in the midst of the COVID-19 emergency, final regulations under Section 901(m) were published. While important for M&A transactions, Section 901(m) had largely been treated as an afterthought in light of the...more
The Tax Cuts and Jobs Act (the Act), signed into law on December 22, 2017, amplifies the effects of certain deduction limitations as they apply to US-taxpaying individuals and other non-corporate investors in private business...more
On December 22, 2017, President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the Tax Bill). The Tax Bill made significant changes to corporate taxation, including, among other...more
As discussed in Eversheds Sutherland (US) LLP’s Quick Call: Legislative and Tax Reforms – What This Could Mean for Business Development Companies, Congress is currently negotiating a tax reform package that, if passed,...more
Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more
The Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced its first 13 issue-based campaigns on January 31, 2017. As discussed in a prior Eversheds Sutherland Legal Alert, these...more
On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more
3/6/2014
/ Capital Gains ,
Corporate Taxes ,
Employee Benefits ,
Energy Sector ,
Executive Compensation ,
Foreign Nationals ,
Income Taxes ,
Insurance Industry ,
Net Investment Income ,
Partnerships ,
Real Estate Market ,
REIT ,
RICs ,
S-Corporation ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Tax Returns
In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more