Kevin J. Feeley
McDermott Will & Emery
Articles
GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders
USA - January 30 2018 The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for…
Treasury finalizes regulations on the varying interests rule under Section 706
USA - October 19 2015 On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d)…
Proposed regulations require significant entrepreneurial risk for a service partner's income to be a distributive share
USA - August 18 2015 On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A)…
Section 752 proposed regulations regarding partnership recourse liabilities and rules for related persons
USA - January 27 2014 On December 13, 2013, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations under Section 752 regarding…
Items of interest in recently finalized regulations on noncompensatory partnership options
USA - March 21 2013 This article highlights items that may be of interest to private equity funds regarding recently finalized regulations on the tax treatment of…
