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Deducting Success Fees in M&A Sell-Side Transactions: Guidance for Private Equity Portfolio Companies

In a typical sale of a private equity portfolio company, sell-side success fees payable to bankers and financial advisors represent one of the most significant transaction costs. Although most types of success fees are...more

IRS Issues Direct Pay and Transferability Proposed Regulations

On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable...more

COVID-19 Disaster Relief Payments Under Section 139

In the wake of the COVID-19 pandemic and shelter-in-place orders, businesses are considering ways to assist employees and other workers who are financially burdened by the crisis....more

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more

IRS Outlines New Process for Voluntary Disclosures

On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more

IRS Updates Golden Parachute Audit Guide

This is our first of many alerts during 2017 as the new administration signals the rollback of many regulations (e.g., fiduciary rules and pay ratio). We will keep you posted. In January 2017, the Internal Revenue...more

IRS Limits Correction Opportunities under Section 409A Proposed Income Inclusion Regulations and Imposes 20% Penalty

In Chief Counsel Advice 201518013 (May 1, 2015) (the "CCA"), the IRS addresses an executive retention bonus that originally vested after three years and was payable in equal installments on the first two anniversaries of the...more

IRS Issues Final Regulations and New Proposed Regulations Regarding Withholding on Derivatives on U.S. Stocks

On December 5, 2013, the Internal Revenue Service ("IRS") issued final regulations (the "Final Regulations") and proposed regulations (the "2013 Proposed Regulations") under section 871(m), which address withholding on...more

IRS Issues Temporary Regulations on the Application of the Straddle Rules to Debt Instruments

On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more

10/16/2013  /  Debt , Foreign Currency , IRS

IRS Confirms its Position that Settlement Payments Allocated to Attorneys’ Fees are Not Wages

Employers frequently ask whether the portion of an employment-related settlement allocated to attorneys’ fees must be treated as wages and subjected to income and employment tax withholding and Form W-2 reporting where a...more

9/17/2013  /  Attorney's Fees , IRS , Settlement , Wages
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