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.
The Treasury Department and IRS in April released a second set of proposed regulations governing tax incentives for investment in “qualified opportunity zones.” We expect the new rule...
The 2017 Tax Cuts and Jobs Act offers generous tax incentives for taxpayers investing in “qualified opportunity funds” (“QOFs”)—entities that invest in businesses located within...
The new tax act signed into law on December 22, 2017, popularly known as the Tax Cuts and Jobs Act (“TCJA”), affects U.S. real estate businesses in significant ways. For example, unde...
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...
On January 23, Governor Cuomo introduced proposed legislation to the New York State Legislature implementing his 2017-2018 budget proposal. One proposal (contained in the Revenue Article...
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...
