Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more
12/18/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Business Judgment Rule ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Subpart F ,
Treasury Regulations
Significant Changes in US Tax System Likely -
In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more
12/13/2016
/ Corporate Taxes ,
Debt-Equity ,
Deferred Compensation ,
International Tax Issues ,
IRS ,
REIT ,
SALT ,
Section 409A ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK
Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more