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
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
Aspects of the current proposals could significantly alter the US taxation of investment funds, sponsors, and investors.
Key Points:
..Major changes to US tax laws on business tax rates, interest deductibility, and...more