On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more
6/15/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Energy Tax Incentives ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Issues ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more
4/2/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
CARES Act ,
Controlled Foreign Corporations ,
Coronavirus/COVID-19 ,
Debt Restructuring ,
EBITDA ,
GILTI tax ,
High-Yield Markets ,
Interest Income ,
International Tax Issues ,
Net Operating Losses ,
Relief Measures ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Relief
On March 27, 2020, Congress approved the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) to provide financial assistance to individuals and businesses, which in aggregate greatly exceeds the financial package...more
3/31/2020
/ Airlines ,
Banks ,
Capital Markets ,
CARES Act ,
Commercial Tenants ,
Community Banks ,
Coronavirus/COVID-19 ,
Economic Stimulus ,
Families First Coronavirus Response Act (FFCRA) ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Federal Grants ,
Federal Loans ,
Federal Reserve ,
Food and Drug Administration (FDA) ,
Forbearance Agreements ,
Foreclosure ,
Health Care Providers ,
Health Insurance ,
Landlords ,
Life Sciences ,
Medical Devices ,
Mergers ,
Mortgages ,
National Security ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Personal Protective Equipment ,
Pharmaceutical Industry ,
Prescription Drugs ,
Property Owners ,
Qualified Immunity ,
Relief Measures ,
Small Business ,
Small Business Loans ,
Supply Chain ,
Tax Credits ,
Tax Deductions ,
Tax Deferral ,
Tenants ,
Unemployment Insurance ,
Virus Testing
On May 23, 2018, the Department of the Treasury and the Internal Revenue Service (IRS) issued Notice 2018-54, stating that proposed regulations will be issued addressing the deductibility of certain payments made by taxpayers...more
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
Reorganizations ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions
On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more