On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more
3/28/2024
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Digital Assets ,
Excise Tax ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Liquidation ,
NIIT ,
Property Tax ,
Tax Policy ,
Tax Reform
On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more
11/13/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Financial Services Industry ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Reform
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC...more
5/31/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Distribution Rules ,
Final Rules ,
Financial Guarantee Requirements ,
IRS ,
Multinationals ,
New Regulations ,
Section 956 ,
Stocks ,
Tax Cuts and Jobs Act ,
Voting Shares
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more
1/28/2019
/ Anti-Abuse Rule ,
BEPS ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
IRS ,
Parent Corporation ,
Proposed Regulation ,
Subpart F ,
Tax Reform
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more
12/6/2018
/ Anti-Abuse Rule ,
Business Taxes ,
C-Corporation ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
PFIC ,
Proposed Regulation ,
REIT ,
REMIC ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more
11/19/2018
/ Borrowers ,
Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
Foreign Subsidiaries ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Tax Deductions ,
Tax Exemptions ,
Tax Reform ,
U.S. Treasury
n October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”) that are likely to allow many controlled foreign corporations...more
11/15/2018
/ Acquisitions ,
Borrowers ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
International Tax Issues ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
U.S. Treasury
On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation deemed to have been received by a registered investment company (a “RIC”) under...more
9/24/2018
/ Controlled Foreign Corporations ,
Excise Tax ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
IRS ,
Registered Investment Companies (RICs) ,
REIT ,
Revenue Procedures ,
Subpart F ,
Tax Cuts and Jobs Act
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more
2/12/2018
/ Acquisitions ,
Base Erosion Tax ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Subsidiaries ,
GAAP ,
GILTI tax ,
International Tax Issues ,
Mergers ,
Net Operating Losses ,
Pass-Through Entities ,
Section 956 ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Reform
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more
1/17/2018
/ Base Erosion Tax ,
Carried Interest ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Taxpayers ,
Income Taxes ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Deductions
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee...more
12/19/2017
/ 501(c)(3) ,
Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Excise Tax ,
Income Taxes ,
Individual Mandate ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
PFIC ,
REIT ,
Section 179 Property ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
UBIT
In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more
12/12/2017
/ 401k ,
501(c)(3) ,
501(c)(6) ,
Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Excise Tax ,
Income Taxes ,
Individual Mandate ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
PFIC ,
Popular ,
Proposed Legislation ,
REIT ,
Section 1031 Exchange ,
Section 179 Property ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
UBIT
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more
11/20/2017
/ 401k ,
Adjusted Gross Income ,
Affordable Care Act ,
Alternative Minimum Tax ,
Charitable Deductions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Employee Benefits ,
Excise Tax ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Independent Contractors ,
Individual Mandate ,
IRS ,
New Legislation ,
Pass-Through Entities ,
Personal Property Tax ,
PFIC ,
Popular ,
REIT ,
S-Corporation ,
Section 179 Property ,
Senate Finance Committee ,
Shared Responsibility Rule ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates