With the likely increased borrowings or refinancing of debt as a result of the COVID-19 crisis, multinational companies should consider the impact of changes in U.S. tax law made in 2018. As a result of these changes, U.S....more
On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more
12/11/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Final Rules ,
GILTI tax ,
International Tax Issues ,
IRS ,
Netting Agreements ,
Popular ,
Proposed Regulation ,
REIT ,
TLAC ,
U.S. Treasury
Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected -
On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more
11/5/2019
/ Acquisitions ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Debt Instruments ,
Income Taxes ,
International Tax Issues ,
IRS ,
Mergers ,
Popular ,
Preamble ,
Proposed Regulation ,
Recordkeeping Requirements ,
Required Documentation ,
Section 385 ,
Temporary Regulations ,
U.S. Treasury