On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”).
The House Draft Bill is primarily...more
5/13/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Legislative Agendas ,
Proposed Legislation ,
Regulatory Agenda ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Ways and Means Committee
On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more
On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more
On December 11, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”), announcing their intention to issue proposed regulations that will address...more
Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more
On October 13, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the “Regulations”) under sections 1502 and 1503 of the Internal Revenue Code...more
On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more
On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more
10/3/2019
/ 1099s ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Cuts and Jobs Act
On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more
9/19/2019
/ Acquisitions ,
Change of Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Sale of Assets ,
Startups ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Venture Capital
On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more
6/20/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Partnership ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Multinationals ,
Partnerships ,
Private Equity Funds ,
Proposed Regulation ,
Subpart F ,
U.S. Treasury
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more
On November 26, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated regulations regarding the new section 163(j) limitation on business interest deductions. Section 163(j) was modified as...more
On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations (the Proposed Regulations) under section 956 of the Internal Revenue Code of 1986,...more
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
On December 19, 2017, the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Bill”). The House of Representatives passed the Bill on December 20, 2017. This follows the release by the conference committee of the...more
On December 19 and 20, 2017, both the House and the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Tax Reform Act”), which is expected to be signed by the President. The House of Representatives had passed...more
On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more
11/20/2017
/ Business Income ,
Corporate Taxes ,
EBITDA ,
Energy Tax Incentives ,
Estate Tax ,
Foreign Corporations ,
International Tax Issues ,
Legislative Agendas ,
Local Taxes ,
Mortgage REITS ,
Property Tax ,
Proposed Legislation ,
Repatriation ,
Shareholders ,
Standard Deduction ,
State Taxes ,
Tax Credits ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, the House Republicans released their plan for comprehensive tax reform, the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Tax Reform Bill”). Prior to this release, Congressional Republicans and the Trump...more
The House Committee on Ways and Means released today its proposed legislative language (the “House Proposal”) implementing, in large part, the framework for tax reform issued by the so-called “Big Six” on September 27, 2017....more
On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more
On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more
The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more
The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more
On April 26, the Trump Administration made its much-anticipated release of several “core principles” of its tax plan. In doing so, the administration affirmed its desire to enact comprehensive corporate and individual tax...more
The election of Donald Trump in November has substantially increased the likelihood of major tax reform in the near future. While it is uncertain what shape such reform will take, there has been renewed interest in the...more