On March 18, 2020, President Trump signed the Families First Coronavirus Response Act (H.R. 6201) (the Act) into law, authorizing certain relief to employees and small and midsize businesses pertaining to the COVID-19...more
On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more
11/18/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bifurcation ,
Controlling Stockholders ,
Debt ,
Debt-Equity ,
Debtor-Creditor ,
Distribution Rules ,
Equity ,
Identity of Interest ,
IRS ,
New Regulations ,
Regulatory Standards ,
Rulemaking Process ,
Section 385 ,
Stocks ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Transaction expenses, including fees for legal counsel, accountants, financial advisors, brokers and other third parties, are an ineluctable aspect of mergers and acquisitions. The ability of parties to deduct at least a...more
On Oct. 9, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (the Proposed Regulations) providing taxpayers with broad and flexible guidance on the tax...more
10/23/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Debt Instruments ,
Income Taxes ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
IRS ,
Libor ,
Proposed Regulation ,
REMIC ,
Rulemaking Process ,
Secured Overnight Funding Rate (SOFR) ,
Tax Planning ,
U.S. Treasury
On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more
10/7/2019
/ Cloud Computing ,
Data Transfers ,
Digital Assets ,
Digital Platforms ,
Digital Services ,
Factoring Transactions ,
IaaS ,
IRS ,
PaaS ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
SaaS ,
Software ,
Tax Liability ,
Tax Planning ,
U.S. Treasury