On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more
On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more
On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more