On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May 22, 2025 (the House...more
Background -
On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more
9/28/2020
/ Business Taxes ,
CARES Act ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Legitimate Business Interest ,
Regulatory Requirements ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
On July 31, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REGS-107213-18) (Proposed Regulations) governing the treatment of “carried interests” (also...more
On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more
On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more
1/2/2020
/ Broker-Dealer ,
Dividend-Equivalent Transactions ,
Dividends ,
Final Rules ,
Foreign Persons ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Popular ,
Qualified Derivatives Dealers (QDDs) ,
Rulemaking Process ,
Section 871(m) ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
U.S. Treasury ,
Withholding Tax
On Oct. 1, the Internal Revenue Service (the Service) issued Revenue Procedure 2019-40 (the Revenue Procedure), which offers guidance relating to ownership by certain U.S. persons of stock in “controlled foreign corporations”...more
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more
Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more
11/16/2018
/ Collateral ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Foreign Subsidiaries ,
Internal Revenue Code (IRC) ,
IRS ,
Lenders ,
Parent Corporation ,
Proposed Regulation ,
Section 956 ,
Tax Deductions ,
Tax Planning ,
Voting Securities