On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more
1/23/2025
/ BEPS ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
OECD ,
Tax Credits ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more
Introduction and Summary -
On March 28, 2022, the Biden Administration proposed changes to the U.S. international tax rules.
In short, the Biden Administration proposed to:
Enact a 15% minimum “undertaxed profits...more
On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.)...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 May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
5/23/2019
/ FIRPTA ,
Foreign Persons ,
Income Taxes ,
International Tax Issues ,
IRS ,
K-1 ,
Partnerships ,
Proposed Regulation ,
Reporting Requirements ,
Shareholders ,
Withholding Requirements
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more