What if? As massive as the CARES Act is, there was one tax section that was left out of the final version. Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
Our Federal Tax Group examines the signature difference brought about by tax reform’s opportunity zone regime.
Comparison to empowerment zones and enterprise communities -
How the new regime is being used.
How seriously...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.
- Selling a U.S. sub versus selling a CFC
- GILTI as a new option over Subpart...more
Cash is king in this year’s M&A deals. Our Federal Tax Group investigates the tax implications behind these all-cash deals and what dangers may lie ahead.
- Few stocks are held by taxable persons
- First-step mergers
- A...more