In light of the many questions our clients have been asking about the legal implications of the coronavirus (COVID-19) crisis and government responses to the pandemic, Davis Polk this week…
Davis Polk has prepared two memos describing key portions of the bill just signed into law: the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In this memo, we cover tax…
With the release of Notice 2020-18, the IRS has now expanded the limited relief it previously granted three days ago in Notice 2020-17 with respect to Federal income tax payments (including…
These rush overnight bullets describe the Senate Republican proposal for Phase 3 of the government’s stimulus response to the coronavirus (COVID-19) emergency. The rush summary describes…
Alternative tests are available to permit a “tack-on” offering to achieve tax fungibility even where the new notes are issued with more than de minimis OID.
Yesterday, in response to the coronavirus (COVID-19) emergency, the IRS granted a three-month extension for corporate and other taxpayers to make certain federal income tax payments that…
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’s…
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. The TCJA…
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…
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 equity…
