On Tuesday, December 27, the IRS released a notice that describes proposed regulations that the IRS intends to issue addressing the application of the 1% stock repurchase excise tax that ...
On August 7, 2022, the United States Senate approved the Inflation Reduction Act of 2022 (H.R. 5376), an energy and healthcare bill that includes new tax provisions, including a new corpo...
On July 27, Sens. Schumer and Manchin announced an agreement on the Inflation Reduction Act of 2022. Key tax provisions include (1) imposing a 15% corporate AMT on the adjusted book inco...
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 ...
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 wee...
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 (includi...
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 describe...
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 ...
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.
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...
