On October 12, 2020, the Internal Revenue Service issued Revenue Procedure 2020-44 (the Revenue Procedure) providing additional guidance related to the transition from an interbank offered rate (IBOR) to another replacement...more
On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more
10/14/2020
/ Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Popular ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On June 5, 2020, the U.S. Internal Revenue Service (the IRS) issued proposed regulations on Section 4960 of the Internal Revenue Code of 1986, as amended (the “Proposed Regulations”). The Proposed Regulations are “intended to...more
On April 13, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-26 (the Revenue Procedure) that provides guidance with respect to certain forbearances and related modifications of mortgages as a result...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
12/17/2019
/ Controlled Foreign Corporations ,
Corporate Counsel ,
Corporate Taxes ,
Final Rules ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Popular ,
Subpart F ,
Tax Cuts and Jobs Act ,
Treasury Regulations ,
U.S. Treasury
On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more
12/11/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Final Rules ,
GILTI tax ,
International Tax Issues ,
IRS ,
Netting Agreements ,
Popular ,
Proposed Regulation ,
REIT ,
TLAC ,
U.S. Treasury
Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected -
On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more
11/5/2019
/ Acquisitions ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Debt Instruments ,
Income Taxes ,
International Tax Issues ,
IRS ,
Mergers ,
Popular ,
Preamble ,
Proposed Regulation ,
Recordkeeping Requirements ,
Required Documentation ,
Section 385 ,
Temporary Regulations ,
U.S. Treasury