Andrew M. Eisenberg

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Internal Revenue Code Section 336(e) elections: basic overview

USA - September 13 2013 The U.S. Treasury Department recently issued final regulations allowing certain taxpayers to make a special election to treat a disposition of…

Lester W. Droller, Patrick J. Browne Jr..

Demystifying the Tax Provisions of the TPP

Global, USA - August 22 2016 International trade watchers have high hopes for the Trans-Pacific Partnership Agreement (“TPP”) and its potential impact on business taxes and, by…

Treasury Releases Final Debt/Equity Regulations

USA - October 20 2016 On October 13, 2016, the U.S. Treasury Department released final debt/equity regulations under section 385 of the Internal Revenue Code aimed…

Edward T. Kennedy, Joseph A. Goldman, Scott M. Levine.

IRS Opens Pilot Program on Tax-free Spin-offs

USA - October 6 2017 On September 21, 2017, the Internal Revenue Service ("IRS") released Revenue Procedure 2017‑52, establishing a pilot program for issuing private…

Candace A. Ridgway, L. Matthew Waterhouse, Richard M. Nugent, Ross E. Poulsen, Scott M. Levine.

Treasury Releases Significant Temporary Anti-Inversion Regulations and Proposed Earnings Stripping Regulations

USA - April 11 2016 On April 4, 2016, the U.S. Treasury Department released two significant packages of U.S. federal tax regulations. T.D. 9761 contains temporary…

Edward T. Kennedy, Robert A. Profusek, Scott M. Levine.