Corporate Taxes, Parent Corporation, Tax Cuts and Jobs Act

No surprises under the tree as IRS concludes no normalization violation in use of revised composite depreciation rate lives to...

Eversheds Sutherland (US) LLP on 12/23/2021

On December 17, 2021, the IRS released Private Letter Ruling 202150003 where it concluded that a Taxpayer would not violate the normalization rules if it ratably amortized its Protected EDIT (defined below) pursuant to an...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 and IRS Issue Final Regulations on Inversions

A&O Shearman on 7/24/2018

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

Impact of US Tax Reform on Insurance Companies

Skadden, Arps, Slate, Meagher & Flom LLP on 2/20/2018

On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

Skadden, Arps, Slate, Meagher & Flom LLP on 1/19/2018

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions