New guidance clarifies certain key points on implementing the 1% tax that generally applies to public company stock buybacks and the 15% corporate minimum tax that generally applies to corporations with book income exceeding...more
Beginning in 2023, an excise tax of 1% will apply to public company stock buybacks and a 15% corporate minimum tax generally will apply to corporations with book income exceeding $1 billion.
Key Points:
..Public...more
8/22/2022
/ Acquisitions ,
Alternative Minimum Tax ,
Corporate Taxes ,
Derivatives ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
Mergers ,
Multinationals ,
Publicly-Traded Companies ,
Share Buybacks ,
Share Classes ,
Special Purpose Acquisition Companies (SPACs) ,
Stock Options ,
Stock Repurchases
The IRS has issued crucial guidance on procedures to implement tax provisions of the recently enacted CARES Act.
Key Points:
..Allows a five-year carryback for net operating losses (NOLs) generated in 2018, 2019, and...more
Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences.
Key Points:
..Issuers may incur immediate income in the...more
The newly enacted CARES Act attempts to lessen taxpayers’ federal income tax obligations and increase their cash flow during the COVID-19 pandemic.
Key Points:
..Allows a five-year carryback for net operating losses...more
Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax.
On May 23, 2019, the US Treasury and Internal...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
But Holding Period and Other Requirements Add Complexity -
On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct.
On August 6, 2018, the US Tax Court decided...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
The new tax rules are expected to have an immediate impact on leveraged companies and leveraged finance transactions.
On December 22, 2017, President Trump signed into law the “Tax Cuts and Jobs Act” (the Act).1 This...more
Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications.
Key Points:
..The bill adopts, with some modifications, earlier US House and Senate tax reform...more
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details.
On September 27, a group of Trump Administration and Congressional leaders...more
The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations.
On July 28, 2017, the US Department of the Treasury (Treasury) and...more
Administration and Congressional tax negotiators abandon border adjustment tax, but leave unanswered questions regarding rates, revenues, and taxation of US multinationals.
As Congress heads toward its late summer 2017...more
Decision could open planning opportunities for non-US partners regarding sale of a partnership interest.
The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more
The Trump plan released this week proposes a significant reduction of tax rates applicable to business income (including income earned through pass-through entities) and a territorial system (with a one-time tax on...more
Tax partnerships, including MLPs, seeking to restructure debt face peril and possibility during challenging times.
With the lowest oil prices in more than a decade and the equity markets effectively closed to them, oil...more
By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques.
A pair of revenue rulings the US Internal Revenue Service (IRS)...more