News & Analysis as of

Legitimate Business Interest Business Taxes

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Clarify Business Interest Deduction Limitation

Background - On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more

Morgan Lewis

IRS Provides Guidance on Elections Related to Section 163(j) Business Interest Limitation

Morgan Lewis on

Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more

Alston & Bird

The Tax Act’s New Business Interest Expense Limitation – Dear IRS: Some Guidance, Please?

Alston & Bird on

The Tax Cuts and Jobs Act replaced the earnings stripping rules with a new limitation on deductions for business interest expense. Our International Tax Group examines the new law and what it means for interest expense...more

Orrick, Herrington & Sutcliffe LLP

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

Orrick, Herrington & Sutcliffe LLP

Impact Of The Tax Bill On International Taxation

The recently issued Conference Bill - the final version of Tax Reform - was approved by Congress on December 20, 2017 and signed into law by President Trump. The brief summary below outlines the sweeping changes in...more

Seyfarth Shaw LLP

Tax Reform For REITs And Real Estate Businesses

Seyfarth Shaw LLP on

This is the third issue in a planned series of alerts designed to provide an in-depth analysis on topics related to tax reform. Background On November 2, 2017, House Republicans introduced the Tax Cuts and Jobs Act...more

Orrick, Herrington & Sutcliffe LLP

The Impact on Financing Transactions if the House’s “Tax Cuts and Jobs Act” Passes

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act (“H.R. 1”), and later proposed amendments to the bill on November 3, November 6, and...more

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