On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships:
In new proposed regulations, the IRS identified several...more
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