The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more
On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more
5/6/2024
/ Cross-Border ,
Cross-Border Transactions ,
Excise Tax ,
Internal Revenue Code (IRC) ,
IRS ,
Merger Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Share Buybacks ,
U.S. Treasury
The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more
11/7/2017
/ Acquisitions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Death Tax ,
EBITDA ,
Excise Tax ,
Executive Compensation ,
Foreign Corporations ,
Foreign Earned Income ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Itemized Deductions ,
MACRS ,
Mortgage Interest ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Principal Executive Officer ,
Proposed Legislation ,
REIT ,
Section 409A ,
Shareholders ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Transfer Taxes ,
Trump Administration ,
Ways and Means Committee