As the world continues to adapt to the COVID-19 pandemic, many companies are assessing their liquidity position, general balance sheets, near-term interest payments and debt maturities. One way companies with outstanding debt...more
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act, H.R. 748 (the “CARES Act”) was approved by Congress and signed into law by President Trump. The legislation is approximately 880 pages in length and...more
Last week the IRS issued a revenue ruling, FAQs, and a revision to draft Schedule 1 to Form 1040 regarding various aspects of virtual currency transactions. The guidance is in line with the Treasury 2019-2020 Priority...more
Despite increasing political tensions and evolving trade policies, the U.S. M&A market in 2018 enjoyed its second-best total deal value ever, according to Mergermarket. Activity through the first three quarters appeared...more
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act") into law. Although the individual and collective impact of the Act may not be evident for some time, the Act is generally viewed by the real...more
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). The Act was ostensibly promoted as a means to encourage investment and to promote growth in the U.S. economy, while reducing harmful...more
On December 20, 2017, both the House and the Senate passed H.R. 1 (the “Bill”), which President Trump is expected to sign by January 3, 2018. The Bill dramatically alters the U.S. approach to domestic and international...more
On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more
On December 2, 2017, the Senate passed its version of tax reform legislation (the "Senate Bill"), advancing it to the next stage.
While the House of Representatives passed its version of tax reform (the "House Bill") on...more
On November 2, 2017, the House Ways and Means Committee unveiled the Tax Cuts and Jobs Act (the “Bill”). The Bill could dramatically alter the U.S. approach to domestic and international taxation. Although the possibility of...more
Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more
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
The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more
6/21/2017
/ Audits ,
Bipartisan Budget Act ,
IRS ,
Limited Liability Company (LLC) ,
Local Taxes ,
Partnerships ,
Proposed Regulation ,
Regulatory Freeze ,
TEFRA ,
Trump Administration ,
UPREITS
On April 26, 2017, amidst much anticipation, the Trump administration released its tax plan, entitled “2017 Tax Reform for Economic Growth and American Jobs” (the “Plan”). The Plan was presented at a press conference by...more
On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more
10/24/2016
/ Credit Agreements ,
Creditors ,
Debt Instruments ,
Debt-Equity ,
Debtor-Creditor ,
Disregarded Entities ,
Enforcement ,
Expanded Group Instruments (EGIs) ,
IRS ,
Proposed Regulation ,
Rebuttable Presumptions
Impact of New Legislation -
The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”) has amended Section 1202 of the Code to permanently extend the 100% exclusion for eligible gain on sales of qualified small...more
On June 9, 2014, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued final regulations replacing the “covered opinion” rules under Circular 230. Effective June 12, 2014, the final rules now subject all...more
One silver lining to the American Taxpayer Relief Act of 2012 (“ATRA”) is that it extended the 100% exclusion for capital gain on qualified small business stock (“QSBS”) acquired between 2010 and 2011 to include stock...more