Candace A. Ridgway

Jones Day


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Proposed Treasury Regulations Permit Foreign Subsidiary Credit Support for U.S. Multinational Financings

USA - November 1 2018 The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign…

Brett P. Barragate, Colleen E. Laduzinski, Edward T. Kennedy, Kelly Rubin.

New Immediate Expensing Regulations Present Opportunities and Questions

USA - September 26 2019 Following up on 2018 proposed regulations, the government finalized certain aspects and issued new proposed rules on other aspects of the immediate…

L. Matthew Waterhouse, Richard M. Nugent, Sean E. Jackowitz.

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…

Andrew M. Eisenberg, L. Matthew Waterhouse, Richard M. Nugent, Ross E. Poulsen, Scott M. Levine.

Proposed Rules for Full Expensing of Capital Investments

USA - August 3 2018 Proposed regulations explain the mechanics of immediate expensing ("bonus depreciation") allowing taxpayers to deduct 100 percent of the cost of…

L. Matthew Waterhouse, Richard M. Nugent, Sean E. Jackowitz.