Tax Reform, Tax Exemptions, U.S. Treasury

House Republicans to Large Endowments: “Ask Not What …”

Cadwalader, Wickersham & Taft LLP on 5/28/2025

Under the House’s current draft budget bill, which was released on May 15, 2025, the 1.4% excise tax on private universities’ net investment income would increase up to 21%, effectively negating one of the main benefits of...more

House Passes Tax Package with Several Carved-Back Provisions Relevant to Tax-Exempt Organizations

Ropes & Gray LLP on 5/23/2025

On May 22, 2025 the House of Representatives passed its version of the “One Big Beautiful Bill Act” (the “BBB”). As described in our prior Alert, the proposed package includes several key provisions of particular importance...more

The Possible Repeal of the Tax Exemption of Municipal Bond Interest

Bricker Graydon LLP on 3/12/2025

You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.” This issue...more

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on 12/13/2018

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on 11/19/2018

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

Moore & Van Allen PLLC on 11/14/2018

Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more

Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage

Akin Gump Strauss Hauer & Feld LLP on 10/25/2018

• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more

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