Corporate Taxes, Business Taxes, Interest Rates

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

ASKramer Law on 4/19/2024

When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

Business Taxation of Hedging Transactions Part II: Common Situations

ASKramer Law on 4/12/2024

What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

Weekly IRS Roundup June 5 – June 9, 2023

McDermott Will & Emery on 6/13/2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Emery on 12/18/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on 12/21/2017

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

UK Government Confirms Introduction of New Cap on Interest Deductibility

McDermott Will & Emery on 7/20/2016

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more