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Opportunity Zones: Second Set of Proposed Regulations Provide Clarity

On Wednesday, April 17, 2019, the Treasury Department and the Internal Revenue Service issued a broad, investment-friendly second set of Proposed Regulations (the “Proposed Regulations”) regarding “Qualified Opportunity...more

IRS Guidance on Taxation of Professional Team Trades

The Internal Revenue Service (“IRS”) issued Revenue Procedure 2019-18 that provides a safe harbor provision for professional sports teams that allows a team to treat the value of a traded player, draft pick, or staff members,...more

Base Erosion and Anti-Abuse Tax (BEAT): Government Issues Proposed Regulations

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

Regulations Proposed to Reduce Tax on Income Inclusions Under Section 956

On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations (the Proposed Regulations) under section 956 of the Internal Revenue Code of 1986,...more

Opportunity Zones: Government Issues Proposed Regulations

On Friday, October 19, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding “Qualified Opportunity Zones.” The Qualified Opportunity Zone regime was...more

Opportunity Zones: Treasury and IRS Issue Proposed Regulations

The Treasury Department and the IRS issued today highly anticipated proposed regulations regarding “Qualified Opportunity Zones.” The Qualified Opportunity Zone regime was introduced as part of the Tax Cuts and Jobs Act of...more

Treasury and IRS Issue Final Regulations on Inversions

On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more

Opportunity Zones: A Preliminary Examination

The Tax Cuts and Jobs Act of 2017 (the “Act”) made significant changes to U.S. federal tax law. One of these changes was the establishment of a new tax regime relating to qualified opportunity zones (“Opportunity Zones”)...more

Impact of the Tax Cuts and Jobs Act on the Real Estate Industry

On December 22, 2017, H.R.1, commonly referred to as the Tax Cuts and Jobs Act (“Tax Act”) was signed into law. The Tax Act made the most significant changes to the U.S. tax code since 1986, and will have an effect on...more

Tax Court Rules Family Office Is Engaged in a Trade or Business

On December 13, 2017, in Lender Management, LLC v. Commissioner, the U.S. Tax Court ruled that a family office, Lender Management, LLC (“Lender Management”), was “carrying on a trade or business” as an investment manager...more

Tax Reform Summary for Family Offices

On December 20, 2017, Congress passed the “Tax Cut and Jobs Act,” which was signed into law by President Trump on December 22, 2017. With some exceptions, the law’s provisions generally are effective for tax years beginning...more

Tax Cuts and Jobs Act: House and Senate Pass Tax Reform Bill

On December 19, 2017, the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Bill”). The House of Representatives passed the Bill on December 20, 2017. This follows the release by the conference committee of the...more

House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

House Committee on Ways and Means Releases Tax Reform Proposal

The House Committee on Ways and Means released today its proposed legislative language (the “House Proposal”) implementing, in large part, the framework for tax reform issued by the so-called “Big Six” on September 27, 2017....more

Trump Administration and Congressional Leaders Release Tax Reform Framework

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

Notice 2017-42 Provides for One-Year Extension of Existing Section 871(m) Rules

On August 4, 2017, the Treasury Department and the Internal Revenue Service (the “IRS”) issued Notice 2017-42 (the “New Notice”) providing taxpayers with relief from certain aspects of the final and temporary regulations...more

One-Year Delay to the Application of Section 385 Documentation Rules

On July 28, 2017, the Treasury Department and the IRS announced in Notice 2017-36 (the “Notice”) that they will delay the documentation rules of Treasury regulation section 1.385-2 to debt instruments issued or deemed to be...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Update on US Federal Tax Reform Proposals

On April 26, the Trump Administration made its much-anticipated release of several “core principles” of its tax plan. In doing so, the administration affirmed its desire to enact comprehensive corporate and individual tax...more

House Blueprint’s Destination-Based Cash Flow Tax: A Primer

The election of Donald Trump in November has substantially increased the likelihood of major tax reform in the near future. While it is uncertain what shape such reform will take, there has been renewed interest in the...more

Potential US Tax Reform Could Fundamentally Change the Structure of the US Tax System

With the election of Donald Trump, who pledged during the campaign to usher in fundamental tax reform (including major tax cuts), the Republican majorities in Congress have begun planning major tax changes to the Internal...more

Highly-Anticipated Final Regulations on Related-Party Debt Instruments Issued

On October 13, 2016, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 385 of the Internal Revenue Code (the “Regulations”) that contain rules requiring...more

Spin-Off Revenue Procedure Removes a No-Rule Area and Provides Safe Harbors for Unwinding High Vote/Low Vote Stock Structures

On July 15th, the IRS released Rev. Proc. 2016-40 (the “Rev. Proc.”) removing a recent “no-rule” area with respect to transactions undertaken in anticipation of a spin-off involving high vote/low vote stock classes for the...more

Treasury and IRS Issue New Spin-Off Proposed Treasury Regulations On Device and Active Trade or Business Requirements

On July 14, 2016, the Treasury Department and the IRS issued proposed regulations under Section 355 on spin-off transactions (the “Proposed Regulations”) that provide guidance with respect to the spin-off device prohibition...more

Proposed Regulations on Related-Party Debt Instruments Would Result in Dramatic Adverse Tax Consequences

On April 4, 2016, the US Department of the Treasury and the Internal Revenue Service proposed regulations under section 385 of the Internal Revenue Code that would recharacterize certain related-party debt instruments, in...more

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