Bill on Bankruptcy: Detroit Judge Might Lose Grip on the Case
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
The Israeli legislature promulgated a new Angels Law at the end of July, with the goal of preserving Israel as an attractive hub for investments in high-tech companies by granting various tax incentives. (This temporary order...more
Thirty years after the IRS first acknowledged that taxpayers could receive profits interests for services without immediate tax, the Tax Court has confirmed our long-held belief that the same protection is available for a...more
Does the sale price of intellectual property between related parties reflect its market value? The Tel Aviv District Court deliberated this question in October 2022. The ruling it handed down, which concurs with a series of...more
On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more
A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more
A More Cautious Approach- Compared to the torrid pace of M&A transactions last year, the current year seems rather pedestrian. That is not to say businesses are not being sold; they are....more
This column describes new proposed Code Sec. 163(n) and the proposed general removal of expense allocation to GILTI in the Build Back Better Act (the “BBBA”). This column focuses on the version of the BBBA proposed on...more
The COVID-19 pandemic of 2020 has caused significant financial hardship in the hospitality industry. This alert addresses the tax consequences of a lender and borrower agreeing to restructure a loan by either: (1) reducing...more
Retaining experienced counsel with knowledge of not only proper procedure but how to present a case is critical to prevailing at the Board of Tax Appeals (BTA). Recently, the BTA denied the taxpayer’s claim for a business...more
The economic troubles that many businesses are facing because of the coronavirus (COVID-19) pandemic have given rise to significant interest by investors in acquiring, or investing in funds that acquire, distressed debt...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more
The Massachusetts House of Representatives overwhelmingly voted in favor of a bill to decouple the Massachusetts tax code from a significant federal interest deduction limitation. The federal limitation is contained in...more
Last December we told you about favorable IRS guidance letting P3 contractors and investors keep full tax deductions for interest on debt. The IRS kept a P3-friendly approach in last week’s proposed regulations on “qualified...more
Withholding tax rates on income derived from Eurobonds and lease certificates issued outside of Turkey, on interest payments of Tier II loans and securitization financings; as well as BITT applicable to securitizations backed...more
Contractors and investors in P3s can continue taking a full tax deduction for interest on debt under recent IRS guidance (Revenue Procedure 2018-59, issued November 26). ...more
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more
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
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
Pursuant to the new German investment tax act (GITA) that will take effect of 1 January 2018, domestic and foreign resident investment funds may become subject to German corporate income tax with various German source income...more
UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more
The Impact of The EU General Data Protection Regulation - The EU General Data Protection Regulation 2016/679 (GDPR) was published in the Official Journal of the European Union on 4 May 2016 following the compromise...more
The First Circuit Court of Appeals has ruled that float income is not a plan asset and therefore is not subject to fiduciary and prohibited transaction provisions of ERISA. The decision was written by former Justice Souter...more
Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...more