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...
In this chapter for Global Legal Insights - Blockchain & Cryptocurrency Regulation 2022, Davis Polk partner Gregory Rowland and NYDIG Senior Counsel and former Davis Polk associate Trevor...
Davis Polk partners David Schnabel and Patrick Sigmon and counsel Ethan Goldman recently authored “Key Considerations and Relevant Ambiguities for Fund Managers Under the Final Carried ...
The IRS has issued final regulations on the taxation of carried interest under Section 1061 of the tax code, which was added in the 2017 tax law and provides that capital gain allocated u...
In this chapter for Global Legal Insights - Blockchain & Cryptocurrency Regulation 2021, Davis Polk partner Gregory Rowland and associate Trevor Kiviat examine cryptocurrency investment f...
Last Friday, the IRS and Treasury proposed regulations (the “Carried Interest Regulations”) on the taxation of carried interest under Section 1061 of the tax code. Section 1061 was ad...
The U.S. Supreme Court issued a decision on February 25 that reduces certainty as to which member of a consolidated tax group is entitled to a federal tax refund. In Rodriguez v. FDIC, t...
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...
