News & Analysis as of

Legitimate Business Interest Income 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

Tax Cuts And Jobs Act - Impact On Financing Transactions

The Tax Cuts and Jobs Act (the "Tax Act") was signed into law by President Trump on December 22, 2017. With respect to financing transactions, the relevant changes include the following:...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

Dechert LLP

Proposed Tax Legislation - Highlights for Investment Funds

Dechert LLP on

The final version of the proposed Tax Cuts and Jobs Act (the “Act”) was released on December 15, 2017. This legislation, unless amended again, is expected to be voted on this week in the U.S. House of Representatives and the...more

Hogan Lovells

How are REITs impacted by the Jobs Act?

Hogan Lovells on

On December 15, 2017, the Conference Committee of the U.S. Congress approved the Tax Cuts and Jobs Act (the “Jobs Act”). The Jobs Act is expected to be approved by both Houses of Congress and signed by President Trump. The...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

Cadwalader, Wickersham & Taft LLP

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

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