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Flips from the UK to the US – Key UK and US Tax Considerations

The insertion of a US holding company by way of a share-for-share exchange, whereby the shares in an existing UK company (“UKCo”) are transferred to a new US company (“USCo”) in exchange for shares issued by USCo, is commonly...more

IRS Issues Direct Pay and Transferability Proposed Regulations

On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable...more

Another Cost of COVID-19 Remote Work – States Want their Cut of Payroll Taxes

Many employers now have employees who have shifted from working in the employer’s office to working remotely from home as a result of the COVID-19 pandemic. ...more

Good News for PPP Loan Recipients: Deferrals for Employer Portion of Social Security Tax Now Available

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” (Public Law 116-136)) allows employers and self-employed individuals to defer payment of the employer share of the Social Security tax from March 27,...more

Tax Relief for Businesses under the CARES Act

On March 27, the President signed into law the Coronavirus Aid, Relief, and Economic Security Act or (the ‘‘CARES Act’’ or the “Act”). The Act contains a wide range of provisions to provide relief from the effects of the new...more

Employer Tax Credits in the Families First Coronavirus Response Act

On March 18, 2020, the Families First Coronavirus Response Act (the “Act”) was signed into law. The Act covers a range of emergency relief items, from expanded paid family, medical and sick leave to coverage of COVID-19...more

EU Introduces New Reporting Requirements For Certain Cross-Border Transactions

On May 25, 2018, the Council of the European Union formally adopted Council Directive 2018/822/EU on the reporting of "potentially aggressive" cross-border tax-planning arrangements....more

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

The Impact on Financing Transactions if the House’s “Tax Cuts and Jobs Act” Passes

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act (“H.R. 1”), and later proposed amendments to the bill on November 3, November 6, and...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

100% QSBS Exclusion Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

100% Exclusion for Gains from Qualified Small Business Stock Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

New York State Corporate Tax Law Reform: The Impact on Companies Providing Digital Products

On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime (the "Act"), most notably for out-of-state corporations providing digital products to New...more

IRS Issues Final Regulations and New Proposed Regulations Regarding Withholding on Derivatives on U.S. Stocks

On December 5, 2013, the Internal Revenue Service ("IRS") issued final regulations (the "Final Regulations") and proposed regulations (the "2013 Proposed Regulations") under section 871(m), which address withholding on...more

IRS Issues Temporary Regulations on the Application of the Straddle Rules to Debt Instruments

On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more

10/16/2013  /  Debt , Foreign Currency , IRS
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