On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more
On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the “Code”) in an attempt to align it...more
On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more
10/25/2016
/ Business Taxes ,
Debt Financing ,
Disguised Sales ,
IRS ,
New Regulations ,
Partnership Agreements ,
Partnership Liabilities ,
Partnerships ,
Proposed Regulation ,
Risk Allocation ,
U.S. Treasury
On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more
10/24/2016
/ Credit Agreements ,
Creditors ,
Debt Instruments ,
Debt-Equity ,
Debtor-Creditor ,
Disregarded Entities ,
Enforcement ,
Expanded Group Instruments (EGIs) ,
IRS ,
Proposed Regulation ,
Rebuttable Presumptions
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions (the “Regulations”). Many features of the Regulations had...more
On April 4th, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax...more
On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more
9/18/2015
/ Corporate Taxes ,
Distribution Rules ,
IRS ,
New Guidance ,
Private Letter Rulings ,
REIT ,
Revenue Procedures ,
RICs ,
Shareholders ,
Spinoffs ,
Tax-Free Transfers
On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more