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G7 Tax Agreement Marks Significant Step Toward Global Tax Reform

The agreement builds on the two-pillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy. Key Points: ..Under Pillar One, the largest and most...more

Treasury Department, IRS Issue Final GILTI High-Tax Exception Regulations

The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes. Key Points: ..Taxpayers can elect on an annual basis whether to...more

COVID-19: CARES Act Eases Key US Tax Rules, Throwing a Lifeline to Some Businesses – UPDATE

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

COVID-19: CARES Act Eases Key US Tax Rules, Throwing a Lifeline to Some Businesses

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

Planning for Tax Controversies Before, During and After the Deal: New Dynamics in Cross-Border M&A Under the TCJA

Considerable thought and commentary has been given to the numerous technical features introduced by P.L. 115-97 (Dec. 22, 2017), colloquially referred to as the “Tax Cuts and Jobs Act” (the “TCJA”). Nearly one-and-a half...more

Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability. Key Points: The base erosion and anti-abuse tax (BEAT) proposed...more

New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate...

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

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

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

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more

IRS Launches New Compliance Campaigns on Repatriation of Foreign Earnings and Virtual Currency

LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual Currency transactions. Key Points: ..The IRS continues its efforts to...more

New Guidance Issued for Transition Tax on Deferred Foreign Earnings

Anti-avoidance rules and limitations on application of the stock attribution rules among the topics to be addressed in forthcoming regulations. Key Points - ..Certain transactions intended to reduce transition tax...more

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

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

US Tax Reform: Opportunities and Challenges for Leveraged Finance

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

Congress Passes Tax Reform Legislation, Implementation Imminent

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

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

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

Tax Reform Update: Administration and Congressional Officials Unveil Framework

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

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

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

Tax Reform Update: 4 Issues to Watch as Congress Nears Summer Recess

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

Tax Reform – An Update Based on Recent Statements from the Trump Administration

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

US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups. Key Points: ..Tax reform...more

Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments

Seeking to curb “excessive” use of related-party debt, Treasury and IRS retain basic framework, but significantly narrow the scope, of the Proposed Regulations. On October 13, 2016, the US Department of the Treasury...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements

As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

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