On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
Real Estate Market ,
Safe Harbors ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more
10/25/2016
/ Anti-Inversion Regulations ,
Asset-Backed Securities ,
Capital Markets ,
Collateralized Loan Obligations ,
Disregarded Entities ,
Grantor Trusts ,
IRS ,
Partnerships ,
Securitization ,
Stocks ,
Student Loans ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury ,
Withholding Tax
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more
10/25/2016
/ Asset Stripping ,
CDIs ,
Collateralized Loan Obligations ,
Convertible Debt ,
Debt Instruments ,
Debt-Equity ,
Exemptions ,
Expanded Group Instruments (EGIs) ,
Foreign Issuers ,
Interest Payments ,
Internal Revenue Code (IRC) ,
Inversion ,
IRS ,
Multinationals ,
Required Documentation ,
Stocks ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury
On April 4, 2016, Treasury released new rules making it more difficult for some U.S. companies to invert (“Serial Inversion Regulations”), Proposed Regulations limiting the effectiveness of “earnings stripping” techniques...more
New final regulations(the “Final Regulations”) have been issued clarifying and altering the “qualified performance-based compensation” exception and the transitional “reliance period” exception for newly public companies to...more
Corporate inversions have constituted an active and successful part of the M&A market in 2013 and early 2014, as acquirors have typically traded up on the date of announcement. However, there is now a new urgency for U.S....more
The Treasury Department, in its Fiscal Year 2015 Revenue Proposals (the “Green Book”), has proposed to significantly tighten Section 7874 of the Internal Revenue Code, effective January 1, 2015, reducing the ability of a U.S....more