Practice Mobile Menu Trigger Overview Experience Team Insights Subscribe to insights February 11, 2020 Articles & Books The 16th Amendment, a national wealth tax, and more Davis Polk partner Jeffrey Schwartz authored “The 16th Amendment, a National Wealth Tax, and More” in a recent edition of… January 20, 2020 Articles & Books The objectivity of the reasonable basis defense to tax penalties If a taxpayer underpays taxes because of negligence, a penalty of 20% applies. Treasury regulations provide for an… December 23, 2019 Client Update IRS Issues Proposed Regulations under Section 162(m) On December 16, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code, which generally… September 13, 2019 Client Update Proposed Changes on Loss Carryforwards Are a (R)BIG Deal for M&A On September 9, 2019, the Internal Revenue Service released proposed regulations that, if finalized in their current form,… July 2, 2019 Client Update Proposed Regulations Likely to Stimulate Investment in Qualified Opportunity Zones The Treasury Department and IRS in April released a second set of proposed regulations governing tax incentives for… May 31, 2019 Client Update Recent Cases Address the IRS's Penalty Approval Procedures Section 6751(b) of the tax code requires written approval by an IRS supervisor after an initial determination by an agency… December 12, 2018 Client Update First Guidance on the Application of Section 83(i) - Tax Deferral for Private Corporation Equity Compensation Awards On December 7, 2018, the Treasury Department and the Internal Revenue Service issued Notice 2018-97, which provides initial… October 25, 2018 Client Update Investments in Qualified Opportunity Funds: Newly Proposed Regulations Offer Significant Clarification The 2017 Tax Cuts and Jobs Act offers generous tax incentives for taxpayers investing in “qualified opportunity funds” (… October 25, 2018 Articles & Books Holding Shares Through Partnerships: Some Observations The chargeable gains rules, and other tax legislation, do not deal with partnerships very clearly. In examining partnership… February 2, 2018 Articles & Books Tax Themes in Acquisition Financing This article considers developments in how some of the UK tax issues on lending into UK acquisition finance structures can… Load More
February 11, 2020 Articles & Books The 16th Amendment, a national wealth tax, and more Davis Polk partner Jeffrey Schwartz authored “The 16th Amendment, a National Wealth Tax, and More” in a recent edition of…
January 20, 2020 Articles & Books The objectivity of the reasonable basis defense to tax penalties If a taxpayer underpays taxes because of negligence, a penalty of 20% applies. Treasury regulations provide for an…
December 23, 2019 Client Update IRS Issues Proposed Regulations under Section 162(m) On December 16, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code, which generally…
September 13, 2019 Client Update Proposed Changes on Loss Carryforwards Are a (R)BIG Deal for M&A On September 9, 2019, the Internal Revenue Service released proposed regulations that, if finalized in their current form,…
July 2, 2019 Client Update Proposed Regulations Likely to Stimulate Investment in Qualified Opportunity Zones The Treasury Department and IRS in April released a second set of proposed regulations governing tax incentives for…
May 31, 2019 Client Update Recent Cases Address the IRS's Penalty Approval Procedures Section 6751(b) of the tax code requires written approval by an IRS supervisor after an initial determination by an agency…
December 12, 2018 Client Update First Guidance on the Application of Section 83(i) - Tax Deferral for Private Corporation Equity Compensation Awards On December 7, 2018, the Treasury Department and the Internal Revenue Service issued Notice 2018-97, which provides initial…
October 25, 2018 Client Update Investments in Qualified Opportunity Funds: Newly Proposed Regulations Offer Significant Clarification The 2017 Tax Cuts and Jobs Act offers generous tax incentives for taxpayers investing in “qualified opportunity funds” (…
October 25, 2018 Articles & Books Holding Shares Through Partnerships: Some Observations The chargeable gains rules, and other tax legislation, do not deal with partnerships very clearly. In examining partnership…
February 2, 2018 Articles & Books Tax Themes in Acquisition Financing This article considers developments in how some of the UK tax issues on lending into UK acquisition finance structures can…