Many upstream and midstream companies are grappling with the prospect of severe liquidity constraints due to the rapid deterioration of both the commodity markets and the debt capital markets. While upstream companies have...more
3/24/2020
/ Debt Market ,
International Tax Issues ,
Market Pricing ,
Midstream Contracts ,
Oil & Gas ,
Oil Prices ,
REIT ,
Risk Assessment ,
Tax Liability ,
Tax Planning ,
Upstream Contracts
Many of the core provisions in the Tax Cuts and Jobs Act (TCJA) — including the corporate tax rate reduction and the fundamental reworking of the U.S. international tax regime — were geared toward addressing the uncompetitive...more
1/25/2019
/ Acquisitions ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Cross-Border Transactions ,
GILTI tax ,
Inversion ,
Mergers ,
Multinationals ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
The sweeping tax bill that President Donald Trump signed into law on December 22, 2017, represents the most comprehensive reform of U.S. tax law since 1986. The law makes substantial changes to the taxation of individuals and...more
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
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
Reorganizations ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
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
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions
On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more
10/10/2016
/ Capital Gains ,
Debt Instruments ,
Disguised Sales ,
Internal Revenue Code (IRC) ,
Joint Venture ,
Master Limited Partnerships ,
Non-Recourse Loans ,
Partnership Liabilities ,
Partnerships ,
Publicly-Traded Companies ,
REIT ,
Tax Allocation Agreements ,
Tax Liability ,
Tax-Deferred Exchanges
On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more
8/18/2015
/ Asset Transfer ,
Business Taxes ,
Capital Gains ,
Cost-Sharing ,
Foreign Affiliates ,
Income Taxes ,
IRS ,
Partnerships ,
Related Parties ,
Section 482 ,
Section 6662 ,
Tax Deductions ,
U.S. Treasury
On July 23, 2015, the Internal Revenue Service (IRS) and the Treasury Department proposed regulations that address the tax treatment of certain partnership interests issued in exchange for services. Of particular note, the...more
After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more
4/22/2014
/ Accounting ,
Alternative Minimum Tax ,
Corporate Taxes ,
Debt Restructuring ,
Derivatives ,
Financial Products ,
Foreign Tax ,
Internal Revenue Code (IRC) ,
Partnerships ,
Subpart F ,
Tax Credits ,
Tax Reform ,
Ways and Means Committee
On January 29, 2014, the Internal Revenue Service (the IRS) and the Treasury Department (Treasury) introduced a long-awaited package of proposed regulations (the Proposed Regulations) that would significantly change the rules...more
The first congressional proposals to revamp partnership and S corporation taxation in connection with anticipated tax reform have surfaced. Framed as two alternatives, both options suggest significant, and, in the case of one...more
3/29/2013