News & Analysis as of

U.S. Treasury Interest Payments

Hinshaw & Culbertson LLP

New Supplemental Guidance Issued for PPP Loan Program

On August 4, 2020, the Small Business Administration (SBA) and the U.S. Department of the Treasury released new FAQs to provide further guidance on Paycheck Protection Program (PPP) loan questions and supplement previously...more

White and Williams LLP

IRS Issues Guidance on Tax Impact of PPP Loan Forgiveness Under the CARES Act

The Internal Revenue Service (IRS) recently issued Notice 2020-32 (Notice), which discusses the deductibility of expenses that are funded by a Paycheck Protection Plan (PPP) loan and the subsequent loan forgiveness. Section...more

Bracewell LLP

Proposed Regulations Alter the Scope of the Section 382 Loss Limitation Rules for Recognized Built-in Gains and Losses

Bracewell LLP on

Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more

Latham & Watkins LLP

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Latham & Watkins LLP on

Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Brownstein Hyatt Farber Schreck

Treasury Releases Guidance on Business Interest Deduction Limits

On Nov. 26, 2018, the Department of the Treasury and the Internal Revenue Service issued proposed regulations under Section 163(j) of the Internal Revenue Code regarding the limitation on the deduction for business interest...more

Cadwalader, Wickersham & Taft LLP

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

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