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
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more
The 2017 Tax Cuts and Jobs Act introduced a new Section 163(j) limitation on deducting business interest expense. Specifically, businesses could only deduct net business interest in any given year equal to 30% of adjusted...more
The landmark 335-page Coronavirus Aid, Relief, and Economic Security Act (CARES Act), signed into law on March 27, 2020, is an estimated $2+ trillion package primarily devoted to providing economic relief and stimulus for...more
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
Executive Summary and Takeaway: Trade secrets and confidential information are receiving increasing protection in many states, and as more states perceive this as a "business friendly" issue, this trend will continue and...more
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
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
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