Corporate Taxes, IRS, Cross-Border Transactions

Treasury Finalizes “Killer B” Regulations with Few Adjustments

Cadwalader, Wickersham & Taft LLP on 8/28/2024

On July 17, the U.S. Treasury and IRS released final regulations targeting various inbound cross-border transactions broadly referred to as “Killer B” transactions, marking the end (for now) of a long-running regulatory fight...more

A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures

Cadwalader, Wickersham & Taft LLP on 2/5/2021

Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances of the device requirement for spinoffs and signaled a willingness to relax...more

Skadden's 2020 Insights

Skadden, Arps, Slate, Meagher & Flom LLP on 1/30/2020

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on 12/31/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

Latham & Watkins LLP on 7/26/2018

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

US Tax Reform Enacts the Most Comprehensive Changes in Three Decades

Skadden, Arps, Slate, Meagher & Flom LLP on 1/23/2018

The sweeping tax bill that President Donald Trump signed into law on December 22, 2017, represents the most comprehensive reform of U.S. tax law since 1986. The law makes substantial changes to the taxation of individuals and...more

Proposed Regulations Nix Foreign Goodwill Exception to Tax on Outbound Transfers

Alston & Bird on 11/17/2015

The IRS and Treasury recently issued proposed regulations under Section 367 with bad news for taxpayers. Citing aggressive taxpayer positions, the proposed rules do away with the foreign goodwill exception and restrict the...more

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