The Proposed Regulations allow existing debt and non-debt contracts that now reference LIBOR and other Interbank Offered Rates (IBORs) to transition toward alternative reference rates without triggering tax.
Key...more
10/23/2019
/ Benchmarks ,
Debt Instruments ,
Fair Market Value ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
Libor ,
Proposed Regulation ,
Safe Harbors ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
IRS seeks comments on key technical questions under the 45Q Credit regime that should spur industry growth.
Key Points:
..The 45Q Credit, which was significantly broadened in 2018, provides a tax credit for each metric...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
Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs.
Key Points:
..Investors in qualified opportunity funds may derive significant tax benefits in the...more
11/7/2018
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Deferral ,
U.S. Treasury