On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more
12/30/2022
/ De Minimus Quantity Exemption ,
Fair Market Value ,
Guidance Update ,
Internal Revenue Code (IRC) ,
IRS ,
Minority Shareholders ,
Netting Agreements ,
REIT ,
Share Buybacks ,
Shareholders ,
Special Purpose Acquisition Companies (SPACs) ,
U.S. Treasury ,
Valuation
The recently proposed “Inflation Reduction Act of 2022” includes a proposal (the “carried interest proposal”) to amend the rules under section 1061 of the Internal Revenue Code of 1986, as amended (the “Code”) relating to the...more
Based on the information available as of today, please find below an update regarding the exceptional tax measures implemented in France, Germany, United-Kingdom and United-States to support companies and business in the...more
On February 25, 2020, the United States Supreme Court issued a unanimous opinion vacating a decision by the U.S. Court of Appeals for the Tenth Circuit applying federal common law to determine the allocation of a corporate...more
2/28/2020
/ 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 22, 2019 the Treasury Department and the Internal Revenue Service released regulations (the “Final Regulations”) finalizing and making certain technical changes to proposed regulations (the “Proposed Regulations”,...more
5/29/2019
/ Controlled Foreign Corporations ,
Dividends ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Subsidiaries ,
U.S. Treasury
On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more
4/22/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
REIT ,
Safe Harbors ,
Tax Deferral ,
U.S. Treasury
On October 31, 2018, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) which likely will facilitate (i) the making of loans by foreign corporate subsidiaries to a U.S. parent...more
On October 19, 2018, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under new section 1400Z-2 of the Internal Revenue Code (the “Code”),...more
Ares Management LP (“Ares”) is a publicly traded investment firm that until now has been structured as a “publicly traded partnership” (“PTP”). Specifically, Ares is a Delaware limited partnership that has historically...more
On January 23, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2018-12 (the “Revenue Procedure”) detailing a safe harbor that will permit taxpayers to utilize average-price methods for purposes of...more
On December 22, the President signed the Tax Cuts and Jobs Act (“TCJA”) into law. TCJA changes the taxation of individuals and businesses in many ways. While there are still many open questions to be addressed by technical...more
1/15/2018
/ Capital Gains ,
Capital Investments ,
Corporate Taxes ,
Like Kind Exchanges ,
Medicare ,
Net Operating Losses ,
Pass-Through Entities ,
Popular ,
Real Estate Market ,
REIT ,
Surtax ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
UBTI
On November 2, House Ways and Means Committee Chairman Kevin Brady (R-TX) released the “Tax Cuts and Jobs Act of 2017” (HR 1, or the “Bill”). On November 3, the Chairman’s Mark of the Bill was released, and Chairman Brady...more
In a July 13, 2017 opinion, the United States Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner refused to follow the long-held IRS position found in Revenue Ruling 91-32 (“the “Revenue...more