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
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
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
Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction.
On August 11, 2017, the Internal Revenue Service (IRS)...more
Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules.
On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more
Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes.
On May 3, 2016, the US Treasury Department (Treasury)...more
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
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax
Changes include restrictions on tax-free REIT spinoffs and other reforms generally favorable to REITs and non-US investors in US real estate.
On December 18, 2015, President Obama signed into law the Protecting Americans...more
Proposed regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules.
On May 14, 2014, the Internal Revenue Service (IRS) published in the Federal...more