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Lexology In-Depth - Acquisition And Leveraged Finance

It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more

Responsible Financial Innovation Act Offers Clarity, Safeguards for Digital Assets - Taxation

Latham & Watkins presents a blog series on the Responsible Financial Innovation Act, which was introduced in the US Senate on June 10, 2022, to create a framework for digital assets, cryptocurrency, and blockchain technology....more

The Acquisition and Leveraged Finance Review, 8th Edition - United States

It is fair to say that the acquisition and leveraged finance industry has shown resilience in relation to the difficult global situation arising from the covid-19 pandemic, particularly in comparison to the previous global...more

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

Tax Considerations for Financing and Refinancing Transactions in Turbulent Times

Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences. Key Points: ..Issuers may incur immediate income in the...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

DAC 6 Deadline Nears: What Does the Mandatory Disclosure Regime Mean for Taxpayers and Advisers?

The 31 December deadline for EU Member States to adopt implementing legislation for DAC 6 is fast approaching. Intermediaries and taxpayers must be ready for compliance. By the end of 2019, each Member State of the...more

Final Section 956 Regulations Open the Door to Foreign Credit Support for US Corporate Borrowers

Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax. On May 23, 2019, the US Treasury and Internal...more

Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability. Key Points: The base erosion and anti-abuse tax (BEAT) proposed...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

New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate...

But Holding Period and Other Requirements Add Complexity - On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more

Tax Reforms Fuel US M&A Activity

The fundamental US tax reforms brought in this year by the Tax Cuts and Jobs Act (TCJA) have changed the tax landscape for M&A more significantly than any other legislation in the modern era. Businesses and tax advisors will...more

IRS Previews Upcoming Guidance on Interest Deduction Limitation

The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations. Key Points: ..The 30% Cap (as defined below) will apply at the consolidated group...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

US Tax Reform: Opportunities and Challenges for Leveraged Finance

The new tax rules are expected to have an immediate impact on leveraged companies and leveraged finance transactions. On December 22, 2017, President Trump signed into law the “Tax Cuts and Jobs Act” (the Act).1 This...more

Congress Passes Tax Reform Legislation, Implementation Imminent

Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications. Key Points: ..The bill adopts, with some modifications, earlier US House and Senate tax reform...more

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

Potential legislation would significantly affect businesses across a variety of sectors. Key Points: ..US House and Senate have each passed comprehensive tax reform legislation. ..Proposals would alter fundamental...more

Tax Reform Update: Administration and Congressional Officials Unveil Framework

The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details. On September 27, a group of Trump Administration and Congressional leaders...more

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

Tax Reform Update: 4 Issues to Watch as Congress Nears Summer Recess

Administration and Congressional tax negotiators abandon border adjustment tax, but leave unanswered questions regarding rates, revenues, and taxation of US multinationals. As Congress heads toward its late summer 2017...more

US Tax Court Exempts Gain on Sale of a Partnership Interest

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

Tax Reform – An Update Based on Recent Statements from the Trump Administration

The Trump plan released this week proposes a significant reduction of tax rates applicable to business income (including income earned through pass-through entities) and a territorial system (with a one-time tax on...more

US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups. Key Points: ..Tax reform...more

Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments

Seeking to curb “excessive” use of related-party debt, Treasury and IRS retain basic framework, but significantly narrow the scope, of the Proposed Regulations. On October 13, 2016, the US Department of the Treasury...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

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