On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more
7/18/2025
/ Bonus Depreciation ,
Business Losses ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
New Legislation ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Business Income ,
Real Estate Investments ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration
In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
6/11/2025
/ Banks ,
Borrowers ,
Consumer Financial Products ,
Corporate Taxes ,
Federal Budget ,
Financial Institutions ,
Financial Services Industry ,
Foreign Banks ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Loans ,
Regulatory Requirements ,
Tax Liability ,
Trump Administration ,
Withholding Tax
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more
6/5/2025
/ Federal Budget ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Proposed Amendments ,
Proposed Legislation ,
Real Estate Development ,
Real Estate Investments ,
REIT ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Trump Administration
On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore...more
The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with...more
3/22/2024
/ Bankruptcy Code ,
Commercial Bankruptcy ,
Creditors ,
Debtor-Creditor ,
Debtors ,
Financial Services Industry ,
Insolvency ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Deductions ,
Tax Liability
In April 2022, opportunity zone (OZ) legislation — H.R. 7467 or the Opportunity Zones Improvement, Transparency and Extension Act — was introduced, but not enacted. Among other items, that legislation included proposals to...more
In April, the Department of the Treasury released the much-anticipated second round of Treasury Regulations under section 1400Z-2 of the Internal Revenue Code (April Regulations). This article provides certain highlights of...more
7/1/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Planning
Issuers and their advisors need to be aware of the potential pitfalls and uncertainties of the applicable high-yield discount obligation rules, which can have the effect of permanently disallowing a portion of interest...more