The proposed Tax Cuts and Jobs Act released by the House of Representatives on November 2, 2017 calls into question the position long taken by government pension plans that they are exempt from the unrelated business income...more
Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more
11/7/2016
/ Cross-Border Transactions ,
Debt Financing ,
Debt-Equity ,
Disguised Sales ,
Disregarded Entities ,
Foreign Subsidiaries ,
Inversion ,
IRS ,
Multinationals ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Reclassification Rules ,
Recordkeeping Requirements ,
REIT ,
RICs ,
S-Corporation ,
Subsidiaries ,
U.S. Treasury
Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more