Colleen E. Laduzinski

Jones Day

Articles

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Final and Proposed Regulations Address Deductibility of Business Interest Expense

USA - September 16 2020 On July 28, 2020, the U.S. Treasury Department released final and proposed regulations under section 163(j) of the Internal Revenue Code, which…

Edward T. Kennedy, Richard M. Nugent

Deductibility of Fines and Penalties: New Guidance Leaves Key Questions Unanswered

USA - May 28 2020 Proposed IRS regulations clarify when fines and penalties are deductible but leave important issues unresolved. The U.S. Internal Revenue Service has…

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

Favorable Net Operating Loss Utilization Rules Could be Eliminated

USA - September 17 2019 Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and…

Edward T. Kennedy, Richard M. Nugent, L. Matthew Waterhouse

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, Edward T. Kennedy, Kelly Rubin

Six-month extension of FATCA deadlines—another joy of Summer

USA - July 15 2013 The IRS announced on Friday, July 12, in Notice 2013-43 (the "Notice") that the earliest deadlines under the Foreign Account Tax Compliance Act…

Kent L. Killelea