On July 4, President Trump signed into law H.R. 1, (the “One Big Beautiful Bill Act” (“OBBBA”)), a sweeping legislation package featuring significant changes to U.S. tax law. The OBBBA was passed via a budget reconciliation...more
7/18/2025
/ Bonus Depreciation ,
CFC ,
Charitable Deductions ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Business Income ,
Qualified Small Business Stock ,
Research and Development ,
SALT ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform
Withholding Tax Rules Under Current Law -
Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more
6/13/2025
/ Borrowers ,
Credit Agreements ,
Financial Services Industry ,
Foreign Investment ,
International Tax Issues ,
Lenders ,
Loans ,
Proposed Legislation ,
Tax Liability ,
Tax Reform ,
Withholding Tax
On October 19, 2018, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under new section 1400Z-2 of the Internal Revenue Code (the “Code”),...more
Ares Management LP (“Ares”) is a publicly traded investment firm that until now has been structured as a “publicly traded partnership” (“PTP”). Specifically, Ares is a Delaware limited partnership that has historically...more
On December 22, the President signed the Tax Cuts and Jobs Act (“TCJA”) into law. TCJA changes the taxation of individuals and businesses in many ways. While there are still many open questions to be addressed by technical...more
1/15/2018
/ Capital Gains ,
Capital Investments ,
Corporate Taxes ,
Like Kind Exchanges ,
Medicare ,
Net Operating Losses ,
Pass-Through Entities ,
Popular ,
Real Estate Market ,
REIT ,
Surtax ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
UBTI
On November 2, House Ways and Means Committee Chairman Kevin Brady (R-TX) released the “Tax Cuts and Jobs Act of 2017” (HR 1, or the “Bill”). On November 3, the Chairman’s Mark of the Bill was released, and Chairman Brady...more