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Latham & Watkins LLP

Lexology In-Depth - Acquisition And Leveraged Finance

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It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Goodwin

Luxembourg Tax Authorities Issue Administrative Guidance On Application Of Interest Limitation Rules

Goodwin on

On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more

Goodwin

Luxembourg Circular On Interest Limitation Rules

Goodwin on

On 8 January, 2021, the Luxembourg tax authorities published Circular L.I.R. 168bis/1 on interest limitation rules (the “Circular”). The Circular provides much needed clarity to the interest limitation rules which have...more

Orrick, Herrington & Sutcliffe LLP

Frances Draft 2019 Finance Bill Reforms Interest Deductibility Limitation Rules

The French government presented the draft Finance Bill for 2019 on September 24, 2018. This draft is currently being discussed by the Parliament and is subject to potential changes....more

Jones Day

Draft French Finance Bill for 2019 Reveals Significant Tax Amendments

Jones Day on

The Situation: The first draft of the French government's finance bill for 2019 contains several significant amendments likely to affect key French tax regimes, as well as past and current transactions. The Development:...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IX: Impact on M&A Transactions

Foster Garvey PC on

The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”). Virtually none of...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Sullivan & Worcester

Impact of 2017 Tax Act on Real Estate Activities

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The first, global observation to share is that the real estate industry dodged a lot of potential bullets during the tax reform process and came out smelling like roses – indeed, actually came out ahead, overall, under the...more

Orrick, Herrington & Sutcliffe LLP

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Skadden, Arps, Slate, Meagher & Flom LLP

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Proskauer - Tax Talks

New Tax Law (H.R. 1): Key Highlights Related to Interest Bearing Debt

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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

Orrick, Herrington & Sutcliffe LLP

Energy Taxation: Impact Of The Tax Cuts And Jobs Act

Congress has passed the tax reform bill, known as the "Tax Cuts and Jobs Act", and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law that affect many industries. ...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

McGuireWoods LLP

2017 Tax Act’s Impact on Real Estate Companies and Their Owners

McGuireWoods LLP on

On Dec. 22, President Donald Trump signed into law the 2017 Tax Act, “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018” (H.R. 1). This...more

McGuireWoods LLP

Tax Reform Bill’s Impact on Renewable Energy Projects

McGuireWoods LLP on

On December 22, 2017, President Donald Trump signed into law the tax reform bill, “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018” (H.R.1). The...more

Seyfarth Shaw LLP

Tax Reform For REITs And Real Estate Businesses

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This is the third issue in a planned series of alerts designed to provide an in-depth analysis on topics related to tax reform. Background On November 2, 2017, House Republicans introduced the Tax Cuts and Jobs Act...more

Proskauer - Tax Talks

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference...

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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

Proskauer - Tax Talks

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

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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

Dechert LLP

Senate Passes Tax Reform Bill

Dechert LLP on

The U.S. Senate passed its version of the GOP tax reform bill, the Tax Cuts and Jobs Act (the “Senate Bill”), on Saturday, December 2, 2017. Shortly before approving the Senate Bill, the U.S. Senate adopted a Manager’s...more

Kelley Drye & Warren LLP

Tax Cuts and Jobs Act

The U.S. Senate passed the “Tax Cuts and Jobs Act” early Saturday. The House of Representatives passed its version of this tax legislation on November 16th. The House and Senate will now begin the process of reconciling...more

Proskauer - Tax Talks

House of Representatives Passes the Tax Cuts and Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison...

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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

Cadwalader, Wickersham & Taft LLP

Fifteen Provisions to Watch in the Tax Reform Proposals

On November 14, 2017, Senate Finance Committee Chairman, Orrin Hatch (R-Utah), released his modified tax reform plan (“Senate Bill”), which adopts some of the House Bill proposals (as amended) (“House Bill”), but also...more

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