In a spin-off, a public company separates one or more of its businesses into new, publicly traded companies. For the public company that initiates it, a spin-off can achieve a number of critical business and financial...more
10/11/2019
/ Board of Directors ,
Capital Markets ,
Capital Structures ,
Corporate Governance ,
Corporate Taxes ,
Form 10-K ,
Initial Public Offering (IPO) ,
Proxy Statements ,
Publicly-Traded Companies ,
Shareholder Rights ,
Tax-Free Spin-Offs
New regulations more notable for what they retain than what they change.
Key Points:
..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...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
For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules.
On June 3, 2015, the US Department of the...more
6/11/2015
/ Bright-Line Rule ,
Corporate Taxes ,
Expatriates ,
Foreign Corporations ,
Foreign Ownership ,
GAAP ,
IFRS ,
Inversion ,
IRS ,
Multinationals ,
Pending Legislation ,
Safe Harbors ,
U.S. Treasury
New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions.
On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more