THE SPLIT DOLLARMINATOR!
The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal Revenue Code. To add confusion to the already complicated subject, the...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more