In light of continued negative macroeconomic trends—including but not limited to meaningfully higher global inflation, tightening monetary policy by central banks, volatile energy prices, slowing consumption, continued supply...more
On December 30, 2021, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released a pre-publication version of final regulations (Treas. Reg. § 1.1001-6) addressing the principal tax...more
On October 12, 2020, the Internal Revenue Service issued Revenue Procedure 2020-44 (the Revenue Procedure) providing additional guidance related to the transition from an interbank offered rate (IBOR) to another replacement...more
On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the “Regulations”) permitting taxpayers to waive deductions to reduce or eliminate liability for the...more
On April 13, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-26 (the Revenue Procedure) that provides guidance with respect to certain forbearances and related modifications of mortgages as a result...more
On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more
12/11/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Final Rules ,
GILTI tax ,
International Tax Issues ,
IRS ,
Netting Agreements ,
Popular ,
Proposed Regulation ,
REIT ,
TLAC ,
U.S. Treasury
On October 8, 2019, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a pre-published version of proposed regulations addressing the principal tax consequences related to the...more
10/9/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Debt Instruments ,
FATCA ,
Income Taxes ,
Inter-Bank Offered Rates (IBORs) ,
International Tax Issues ,
IRS ,
Libor ,
Proposed Regulation ,
REMIC ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more
On December 19 and 20, 2017, both the House and the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Tax Reform Act”), which is expected to be signed by the President. The House of Representatives had passed...more
On November 2, 2017, the House Republicans released their plan for comprehensive tax reform, the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Tax Reform Bill”). Prior to this release, Congressional Republicans and the Trump...more