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COVID-19: CARES Act Eases Key US Tax Rules, Throwing a Lifeline to Some Businesses – UPDATE

The IRS has issued crucial guidance on procedures to implement tax provisions of the recently enacted CARES Act. Key Points: ..Allows a five-year carryback for net operating losses (NOLs) generated in 2018, 2019, and...more

COVID-19: CARES Act Eases Key US Tax Rules, Throwing a Lifeline to Some Businesses

The newly enacted CARES Act attempts to lessen taxpayers’ federal income tax obligations and increase their cash flow during the COVID-19 pandemic. Key Points: ..Allows a five-year carryback for net operating losses...more

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

OECD Publishes Final BEPS Project Reports

A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures. On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

Treasury Announces Inversion Regulations; Reach Extends to Other Cross-Border M&A

New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions. On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more

The M&A Word of the Day® from the Book of Jargon® – Global Mergers & Acquisitions Is Inversion [Video]

Latham & Watkins partner Diana Doyle explains the M&A term inversion, an acquisition transaction in which a target corporation from one jurisdiction (e.g., US) is acquired by a corporation from another jurisdiction. For...more

1/8/2014  /  Inversion
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