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
On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...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 May 13, 2020, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) released regulations finalizing previously proposed regulations under Internal Revenue Code Section 385 regarding the...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 Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more
11/18/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bifurcation ,
Controlling Stockholders ,
Debt ,
Debt-Equity ,
Debtor-Creditor ,
Distribution Rules ,
Equity ,
Identity of Interest ,
IRS ,
New Regulations ,
Regulatory Standards ,
Rulemaking Process ,
Section 385 ,
Stocks ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
On Oct. 9, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (the Proposed Regulations) providing taxpayers with broad and flexible guidance on the tax...more
10/23/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Debt Instruments ,
Income Taxes ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
IRS ,
Libor ,
Proposed Regulation ,
REMIC ,
Rulemaking Process ,
Secured Overnight Funding Rate (SOFR) ,
Tax Planning ,
U.S. Treasury
On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more
10/7/2019
/ Cloud Computing ,
Data Transfers ,
Digital Assets ,
Digital Platforms ,
Digital Services ,
Factoring Transactions ,
IaaS ,
IRS ,
PaaS ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
SaaS ,
Software ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
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