New regulations more notable for what they retain than what they change.
Key Points:
..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more
The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime.
Key Points:
..Taxpayers can deliver IRS Form W-9 or an affidavit to establish...more
Summary of private equity firms’ compliance obligations, discussion of notable developments in 2017, and outlook for 2018.
US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more
Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups.
Key Points:
..Tax reform...more
A roadmap through the various regulations and tax implications can help ensure a successful offering.
Non-US private equity sponsors frequently seek to market their funds to US institutional investors. However, the...more
Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures.
On September 15, 2016, the US Internal Revenue Service (the IRS) issued...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