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New Section 956 Regulations Expand Scope of the New Participation Exemption But May Expose Borrowers to Increased Collateral...

On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the “Code”) in an attempt to align it...more

Tax Reform: Key Considerations for Real Estate Investment Trusts

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act") into law. Although the individual and collective impact of the Act may not be evident for some time, the Act is generally viewed by the real...more

Tax Reform: Key Considerations for M&A, Private Equity & Venture Capital Transactions

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). The Act was ostensibly promoted as a means to encourage investment and to promote growth in the U.S. economy, while reducing harmful...more

U.S. Tax Reform Bill Passes Both Houses; Awaits President's Signature

On December 20, 2017, both the House and the Senate passed H.R. 1 (the “Bill”), which President Trump is expected to sign by January 3, 2018. The Bill dramatically alters the U.S. approach to domestic and international...more

Trump Administration Officials and Congressional Leaders Release “Unified Framework” for Tax Reform

On September 27, 2017, a group of top Trump administration officials and key leaders from the House and Senate released an aspirational outline for future tax reform referred to as the “Unified Framework” (the “Framework”). ...more

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