On January 17, 2025, news sources reported that Republican members of Congress circulated a detailed list of legislative policy options, including tax proposals. This blog post summarizes some of the tax proposals and...more
The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type.
In proposed regulations (“the...more
10/16/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Comment Period ,
Debt Instruments ,
Fair Market Value ,
Financial Instruments ,
Income Taxes ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
IRS ,
Libor ,
New Guidance ,
Proposed Regulation ,
REMIC ,
Safe Harbors ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for...more
4/26/2019
/ Fair Market Value ,
Financial Statements ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Revenue Procedures ,
Section 1031 Exchange ,
Spectator Sports ,
Sports ,
Tax Cuts and Jobs Act ,
Tax Reform
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform