On Tuesday, December 27, the IRS released a notice that describes proposed regulations that the IRS intends to issue addressing the application of the 1% stock repurchase excise tax that ...
Consensus has emerged among policymakers, regulators and the industry on the need for sound regulation of digital assets that supports innovation and inclusion. This deck looks across the...
The IRS has issued final regulations on the taxation of carried interest under Section 1061 of the tax code, which was added in the 2017 tax law and provides that capital gain allocated u...
The U.S. Supreme Court issued a decision on February 25 that reduces certainty as to which member of a consolidated tax group is entitled to a federal tax refund. In Rodriguez v. FDIC, t...
On September 9, 2019, the Internal Revenue Service released proposed regulations that, if finalized in their current form, would in many cases dramatically reduce the portion of a company...
The Tax Cuts and Jobs Act (“TCJA”), the most significant tax legislation since the Tax Reform Act of 1986, has passed both houses of Congress and awaits the President’s signature. T...
In a decision
released July 13, the U.S. Tax Court held that gain realized by a non-U.S. investor on the disposition of an interest in a partnership that operated a U.S. business was gen...
Tax reform will be one of the top priorities for the 115th Congress. Hopes for pursuing tax reform to a successful conclusion are high, given one-party control of the government (and exu...
On October 13, the IRS and the Treasury Department released final and temporary regulations under section 385 relating to the classification of certain intercompany loans as debt or equit...
On October 13, the IRS and the Treasury Department released final and temporary regulations under section 385 relating to the classification of certain intercompany loans as debt or equit...