On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation deemed to have been received by a registered investment company (a “RIC”) under...more
9/24/2018
/ Controlled Foreign Corporations ,
Excise Tax ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
IRS ,
Registered Investment Companies (RICs) ,
REIT ,
Revenue Procedures ,
Subpart F ,
Tax Cuts and Jobs Act
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more
2/12/2018
/ Acquisitions ,
Base Erosion Tax ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Subsidiaries ,
GAAP ,
GILTI tax ,
International Tax Issues ,
Mergers ,
Net Operating Losses ,
Pass-Through Entities ,
Section 956 ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Reform
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more
1/17/2018
/ Base Erosion Tax ,
Carried Interest ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Taxpayers ,
Income Taxes ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Deductions