While the proposed carried interest regulations clarify key aspects, the proposed rules leave some ambiguity for investment fund managers.
Section 1061 is intended to limit long-term capital gain treatment attributable to...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime.
Key Points:
..Taxpayers can deliver IRS Form W-9 or an affidavit to establish...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform