Corporate Taxes, IRS, Interest Payments

Proposed Regulations Alter the Scope of the Section 382 Loss Limitation Rules for Recognized Built-in Gains and Losses

Bracewell LLP on 9/27/2019

Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Latham & Watkins LLP on 12/20/2018

Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on 12/13/2018

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Treasury Releases Guidance on Business Interest Deduction Limits

Brownstein Hyatt Farber Schreck on 12/10/2018

On Nov. 26, 2018, the Department of the Treasury and the Internal Revenue Service issued proposed regulations under Section 163(j) of the Internal Revenue Code regarding the limitation on the deduction for business interest...more

Tax Reform’s Impact on Transportation Finance Transactions

Vedder Price on 8/24/2018

New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on 7/25/2018

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

IRS Previews Upcoming Guidance on Interest Deduction Limitation

Latham & Watkins LLP on 4/4/2018

The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations. Key Points: ..The 30% Cap (as defined below) will apply at the consolidated group...more

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