News & Analysis as of

Tax Deductions Parent Corporation

Rivkin Radler LLP

Business Expenses Paid by Shareholder, But Whose Deduction Is It?

Rivkin Radler LLP on

Constructive Transfers- It is axiomatic that the tax treatment of interactions between a closely held business and its owners will generally be subject to heightened scrutiny by the IRS, and that the labels attached to such...more

White & Case LLP

Interest related to leveraged capital reduction or dividend distribution not always tax deductible, according to the Supreme Court

White & Case LLP on

The Supreme Court has ruled that interest on a loan contracted in order to carry out a capital reduction or a dividend distribution when the company lacks the liquidity to do so is not always deductible. It is crucial that...more

Hogan Lovells

Upstream guarantees and security by foreign subsidiaries of a U.S. corporate borrower may now be available without adverse U.S....

Hogan Lovells on

Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more

Kramer Levin Naftalis & Frankel LLP

IRS Paves the Way for Lenders to Obtain Guarantees and Collateral From (and 100% Stock Pledges of) Foreign Subsidiaries

Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more

Alston & Bird

Guarantees, Debts, and Equity

Alston & Bird on

Our Federal Tax Group reviews the potential pitfalls of seeking deductions for parent guarantees revealed by a recent district court decision. - The district court’s finding - The parent bails out its subsidiary -...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

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

Skadden, Arps, Slate, Meagher & Flom LLP

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

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

Pillsbury Winthrop Shaw Pittman LLP

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

Carlton Fields

Stretched for Resources, the IRS Sets Its Sights on Small Captive Insurers

Carlton Fields on

A "captive" insurance company is an insurer formed for the limited purpose of insuring the risks of its non-insurer owner or owners. A captive can be an effective risk-management tool, especially for costly or unconventional...more

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