The question is no longer whether the volatility created by the COVID-19 pandemic will deepen the difficulties businesses and other institutions face in the coming months, but by how much and in what ways. In the past few...more
Significant Changes in US Tax System Likely - In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more
On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more
Recently proposed Treasury regulations, which will likely be finalized this year, promise to alter the tax treatment of a wide range of intercompany financing transactions dramatically, upending nearly a century of law...more