The recently passed One Big Beautiful Bill Act (OBBBA) makes significant and immediate changes to the tax rules surrounding qualified small business stock (QSBS) under Section 1202 of the Internal Revenue Code. These rules...more
The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more
President-elect Donald Trump is set to return to the White House with Republicans narrowly securing both the US Senate and the US House of Representatives. Having control of both chambers positions the party well to pursue...more
12/30/2024
/ Acquisitions ,
Corporate Taxes ,
Cross-Border ,
Mergers ,
Pillar 2 ,
Political Campaigns ,
Tariffs ,
Tax Cuts ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more
8/1/2022
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Investment Partnerships ,
Proposed Legislation ,
Tax Rates
The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that recharacterizes certain net long-term capital gain with...more
The CARES Act bring changes to the net operating loss rules that may impact completed and future corporate transactions...more
The IRS recently issued proposed regulations under Section 199A, a provision enacted as part of tax reform to allow individuals and certain other non-corporate taxpayers to deduct up to 20 percent of qualified business...more
Now that the 2017 tax reform act is law, private equity and M&A professionals must grapple with its sweeping changes and reconcile the new provisions with how they do business. This On the Subject summarizes important...more
1/3/2018
/ Acquisitions ,
Alternative Minimum Tax ,
Business Income ,
C-Corporation ,
Capital Expenditures ,
Corporate Taxes ,
EBITDA ,
International Tax Issues ,
IRS ,
Mergers ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Qualified Small Business Stock ,
S-Corporation ,
Tax Rates ,
Tax Reform ,
Trump Administration
The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more