Business Tax Provisions -
About-Face on Deductibility of PPP Expenses. The CAA overrules the IRS’s previous guidance denying the deductibility of expenses relating to forgiven PPP loans....more
2/3/2021
/ CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Families First Coronavirus Response Act (FFCRA) ,
Federal Loans ,
Financial Stimulus ,
Infectious Diseases ,
New Legislation ,
Paycheck Protection Program (PPP) ,
SBA Lending Programs ,
Tax Credits ,
Tax Deductions ,
Tax Planning
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. ...more
On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
Real Estate Market ,
Safe Harbors ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
On December 20, 2017, the Senate and House of Representatives passed H.R. 1, known as the “Tax Cuts and Jobs Act” (“Tax Reform Bill”). President Trump is expected to sign the Tax Reform Bill by early January. The Tax Reform...more
12/21/2017
/ Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Pending Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more
12/13/2017
/ BEPS ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Popular ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 14, 2017, Senate Finance Committee Chairman, Orrin Hatch (R-Utah), released his modified tax reform plan (“Senate Bill”), which adopts some of the House Bill proposals (as amended) (“House Bill”), but also...more
11/20/2017
/ Carried Interest ,
Corporate Taxes ,
EBITDA ,
Excise Tax ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Partnership Interests ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more
11/9/2017
/ Collateralized Loan Obligations ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Legislative Agendas ,
Legitimate Business Interest ,
Pass-Through Entities ,
Securitization Vehicles ,
Tax Code ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
UBTI
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”) which includes significant changes to the current U.S. federal income tax regime for businesses and...more
11/6/2017
/ Business Taxes ,
Corporate Counsel ,
Corporate Taxes ,
Excise Tax ,
Insurance Industry ,
International Tax Issues ,
Like Kind Exchanges ,
Net Operating Losses ,
Partnerships ,
Related Parties ,
S-Corporation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m). Under the notice, withholding applies only to...more
On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more
10/25/2016
/ Anti-Inversion Regulations ,
Asset-Backed Securities ,
Capital Markets ,
Collateralized Loan Obligations ,
Disregarded Entities ,
Grantor Trusts ,
IRS ,
Partnerships ,
Securitization ,
Stocks ,
Student Loans ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury ,
Withholding Tax
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more
10/25/2016
/ Asset Stripping ,
CDIs ,
Collateralized Loan Obligations ,
Convertible Debt ,
Debt Instruments ,
Debt-Equity ,
Exemptions ,
Expanded Group Instruments (EGIs) ,
Foreign Issuers ,
Interest Payments ,
Internal Revenue Code (IRC) ,
Inversion ,
IRS ,
Multinationals ,
Required Documentation ,
Stocks ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury
On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents”...more
On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more
5/19/2016
/ Beneficial Owner ,
Business Entities ,
Employer Identification Number (EIN) ,
FinCEN ,
Foreign Ownership ,
IRS ,
Money Laundering ,
Mossack Fonseca ,
Offshore Funds ,
Panama Papers ,
Recordkeeping Requirements ,
Reporting Requirements ,
Tax Evasion ,
Tax Haven
I. Introduction -
On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed...more