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New Section 956 Regulations Expand Scope of the New Participation Exemption But May Expose Borrowers to Increased Collateral Requirements

USA - November 9 2018 On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section...

Joy S. MacIntyre, Maureen E. Linch.


Tax Reform: Key Considerations for Real Estate Investment Trusts

USA - January 29 2018 On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act") into law.1 Although the individual and collective impact of the Act...

Clara Lim, Jessica S. Stern, Remmelt A. Reigersman, Thomas A. Humphreys, Shane M. Shelley, Shiukay Hung, Matthew Y. Lau.


Tax Reform: Key Considerations for M&A, Private Equity & Venture Capital Transactions

USA - January 18 2018 On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act").1 The Act was ostensibly promoted as a means to encourage...

Brennan W. Young, Remmelt A. Reigersman, Thomas A. Humphreys, Craig Phillips, Allison Y. Peck, Shane M. Shelley, David B. Strong, Jacob M. Harper, Shiukay Hung, Matthew Y. Lau.


Trump Administration Officials and Congressional Leaders Release "Unified Framework" for Tax Reform

USA - September 28 2017 On September 27, 2017, a group of top Trump administration officials and key leaders from the House and Senate released an aspirational outline for...

Brennan W. Young, Nicole M. Humphrey, Thomas A. Humphreys, David B. Strong.


IRS Issues Final Debt-Equity Regulations

USA - October 21 2016 On October 13th, the Internal Revenue Service ("IRS") followed through on its promise to issue final regulations and temporary regulations under...

Remmelt A. Reigersman, Michelle M. Jewett, Thomas A. Humphreys, Shane M. Shelley, David B. Strong.