On September 9, 2019, the Internal Revenue Service released proposed regulations that, if finalized in their current form, would in many cases dramatically reduce the portion of a company...
The Tax Cuts and Jobs Act (“TCJA”), the most significant tax legislation since the Tax Reform Act of 1986, has passed both houses of Congress and awaits the President’s signature. T...
In a decision
released July 13, the U.S. Tax Court held that gain realized by a non-U.S. investor on the disposition of an interest in a partnership that operated a U.S. business was gen...
Tax reform will be one of the top priorities for the 115th Congress. Hopes for pursuing tax reform to a successful conclusion are high, given one-party control of the government (and exu...
On October 13, the IRS and the Treasury Department released final and temporary regulations under section 385 relating to the classification of certain intercompany loans as debt or equit...
On April 4, 2016, the Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) issued (i) final and temporary regulations addressing inversion transactions (t...
The Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) on April 4, 2016 released proposed regulations under Section 385 of the Internal Revenue Code tha...
On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that concludes that an offshore master fund and its offshore feeder f...
Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends for withholding tax purposes. On December 4, 2013, the Treasury D...
Section 871(m) of the Internal Revenue Code, enacted in 2010, imposes withholding tax on, among other things, “dividend equivalents” paid to foreign counterparties pursuant to “spec...
