It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more
4/5/2024
/ Acquisitions ,
AML/CFT ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Capital Markets ,
Commercial Bankruptcy ,
Corporate Taxes ,
EBITDA ,
Economic Sanctions ,
Financial Markets ,
Foreign Direct Investment ,
Insolvency ,
Interest Payments ,
Leveraged Finance ,
Loan Guaranties ,
Mergers ,
Publicly-Traded Companies ,
Regulatory Requirements ,
Secured Debt ,
Spain ,
Tax Deductions ,
UK ,
Unsecured Debt
Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences.
Key Points:
..Issuers may incur immediate income in the...more
The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability.
Key Points:
The base erosion and anti-abuse tax (BEAT) proposed...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 fundamental US tax reforms brought in this year by the Tax Cuts and Jobs Act (TCJA) have changed the tax landscape for M&A more significantly than any other legislation in the modern era. Businesses and tax advisors will...more
The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations.
Key Points:
..The 30% Cap (as defined below) will apply at the consolidated group...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
The new tax rules are expected to have an immediate impact on leveraged companies and leveraged finance transactions.
On December 22, 2017, President Trump signed into law the “Tax Cuts and Jobs Act” (the Act).1 This...more
Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications.
Key Points:
..The bill adopts, with some modifications, earlier US House and Senate tax reform...more
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details.
On September 27, a group of Trump Administration and Congressional leaders...more
The Trump plan released this week proposes a significant reduction of tax rates applicable to business income (including income earned through pass-through entities) and a territorial system (with a one-time tax on...more
Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups.
Key Points:
..Tax reform...more
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury