News & Analysis as of September 21, 2024

Income Taxes › Inversion

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Build Back Better Act: Comparison of Senate Finance Committee and House Tax Provisions

Cadwalader, Wickersham & Taft LLP on 12/14/2021

Here's a summary of the new tax provisions in the Build Back Better Act proposed by the Senate Finance Committee, as compared to the version that the House passed on November 19, 2021....more

New Proposed Regulations Increase Scrutiny on Related-Party Debt

Dechert LLP on 4/29/2016

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

2014 Year-End Tax Update

Cozen O'Connor on 12/16/2014

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

Focus on Tax Strategies & Developments - November 2014

McDermott Will & Emery on 11/12/2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

New Treasury Regulations Target Corporate Inversions

Orrick, Herrington & Sutcliffe LLP on 10/3/2014

Last week, the Internal Revenue Service and Treasury Department announced a number of new regulations intended to make it more difficult to qualify for tax advantages associated with inversion transactions and reduce certain...more

International Update - Tax Executives Institute PowerPoint Presentation

Troutman Pepper on 4/23/2014

In this Presentation: - Topics - Inversion - Inversions – How Did We Get Here? - Impact Of The §367 Regulations - 2003 – Enactment of §7874 - §7874 - Determining “Ownership” - Treasury Regulation...more

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