On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more
Over the past several months, there has been much speculation regarding potential changes to corporate and individual tax rates. The infrastructure plan released by the White House on Wednesday, March 31, includes a proposed...more
On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...more
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
9/28/2020
/ Business Taxes ,
CARES Act ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Legitimate Business Interest ,
Regulatory Requirements ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more
1/2/2020
/ Broker-Dealer ,
Dividend-Equivalent Transactions ,
Dividends ,
Final Rules ,
Foreign Persons ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Popular ,
Qualified Derivatives Dealers (QDDs) ,
Rulemaking Process ,
Section 871(m) ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
U.S. Treasury ,
Withholding Tax
The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more
3/29/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Global Regulators Increasingly Shifting Focus to Cryptocurrency -
After years of allowing cryptocurrency transactions to fly under the radar, financial market regulators are beginning to turn their attention to virtual...more
2/2/2018
/ Bitcoin ,
Cryptocurrency ,
Digital Currency ,
EU ,
Financial Markets ,
Initial Coin Offering (ICOs) ,
Investment Funds ,
New Legislation ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Token Sales ,
Virtual Currency
The tax reform signed into law by President Trump on Dec. 22 (the Tax Act) presents public companies with several accounting and disclosure challenges. Although companies are still evaluating how they will be affected by the...more
1/2/2018
/ Corporate Taxes ,
Disclosure Requirements ,
Financial Statements ,
Form 8-K ,
Income Taxes ,
New Legislation ,
Publicly-Traded Companies ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more
1/2/2018
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Compensation & Benefits ,
Corporate Taxes ,
Executive Compensation ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Section 162(m) ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On Dec. 20, 2017, the House of Representatives by a vote of 224 to 201 passed the most significant tax legislation in more than three decades. The Senate passed the same legislation earlier in the day....more
On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act. The Senate Budget Committee voted on Nov. 28, 2017, to send the Senate version of the bill to the floor,...more
12/4/2017
/ Alternative Minimum Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...more
1/5/2017
/ Congressional Intent ,
Corporate Taxes ,
Exports ,
Imports ,
Income Taxes ,
Investment Funds ,
Itemized Deductions ,
Legislative Agendas ,
Repatriation ,
Tariffs ,
Tax Rates ,
Tax Reform ,
Trump Administration