In its recent decision in Rodriguez v. Federal Deposit Insurance Corp., No. 18–1269 (Sup. Ct. Feb. 25, 2020), the Supreme Court held that federal courts may not apply the federal common law “Bob Richards Rule” to determine...more
3/12/2020
/ Affiliated-Business Arrangements ,
Appeals ,
Bob Richards Rule ,
Commercial Bankruptcy ,
Consolidated Tax Returns ,
Federal Common Law ,
Federal v State Law Application ,
IRS ,
Jurisdiction ,
Lack of Authority ,
Parent Corporation ,
Remand ,
Rodriguez v Federal Deposit Insurance Corp. ,
SCOTUS ,
State Law Claims ,
Tax Allocation Agreements ,
Tax Refunds ,
Vacated
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more
Recently-finalized, regulations provide that, in determining whether a corporation is a regulated investment company (RIC), amounts the corporation is required to include in income as a result of its investment in foreign...more
On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more
1/2/2018
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Compensation & Benefits ,
Corporate Taxes ,
Executive Compensation ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Section 162(m) ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act. The Senate Budget Committee voted on Nov. 28, 2017, to send the Senate version of the bill to the floor,...more
12/4/2017
/ Alternative Minimum Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The IRS announced in July that it has withdrawn proposed regulations (the net value regulations) that provided guidance regarding corporate formations, reorganizations and liquidations of insolvent corporations. Those...more
The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more