The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that the government intends to issue to target the tax benefits of co...
A draft of the bill that is being considered by Senator Schumer (D-NY) to reduce some of the economic incentives for corporate inversions was made publicly available yesterday. Senator S...
As expected, Senator Carl Levin and thirteen other Democratic Senators yesterday introduced a bill that would significantly limit, for a two-year period, the ability of U.S. corporations ...
The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “Temporary Regulations”) incorporating and expanding upon the ru...
On January 4, 2013, the Sixth Circuit denied the U.S. government’s petition for en banc review of its September 2012 decision in United States v. Quality Stores that certain severance p...
Today the House passed H.R. 4213, “American Jobs and Closing Tax Loopholes Act of 2010.” The bill contains both new proposals and proposals that were included in the Administration’...
On May 20, Democratic House and Senate tax writers released a tax extenders package (H.R. 4213) that includes provisions relating to the taxation of carried interest received by investmen...
This morning, the Obama Administration provided more detail on its previously announced plan to reform the U.S. tax laws relating to the taxation of income earned by foreign subsidiaries ...
The 2009 New York State budget proposed by Governor David Patterson yesterday contains a provision that would, effective January 1, 2009, impose New York tax on carried interest income al...
