In Soroban Capital Partners LP v. Commissioner, the Tax Court held that the statutory exclusion from the imposition of self-employment tax does not automatically apply with respect to the distributive share allocable to...more
On May 13, 2020, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) released regulations finalizing previously proposed regulations under Internal Revenue Code Section 385 regarding the...more
On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more
11/18/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bifurcation ,
Controlling Stockholders ,
Debt ,
Debt-Equity ,
Debtor-Creditor ,
Distribution Rules ,
Equity ,
Identity of Interest ,
IRS ,
New Regulations ,
Regulatory Standards ,
Rulemaking Process ,
Section 385 ,
Stocks ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
On Oct. 1, the Internal Revenue Service (the Service) issued Revenue Procedure 2019-40 (the Revenue Procedure), which offers guidance relating to ownership by certain U.S. persons of stock in “controlled foreign corporations”...more
Transaction expenses, including fees for legal counsel, accountants, financial advisors, brokers and other third parties, are an ineluctable aspect of mergers and acquisitions. The ability of parties to deduct at least a...more
On Oct. 9, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (the Proposed Regulations) providing taxpayers with broad and flexible guidance on the tax...more
10/23/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Debt Instruments ,
Income Taxes ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
IRS ,
Libor ,
Proposed Regulation ,
REMIC ,
Rulemaking Process ,
Secured Overnight Funding Rate (SOFR) ,
Tax Planning ,
U.S. Treasury
On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more
10/7/2019
/ Cloud Computing ,
Data Transfers ,
Digital Assets ,
Digital Platforms ,
Digital Services ,
Factoring Transactions ,
IaaS ,
IRS ,
PaaS ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
SaaS ,
Software ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more