Articles

Results 1 to 5 of 7


IRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactions

USA - December 7 2020 On November 17, 2020, the U.S. Internal Revenue Service (“IRS”) posted new FAQs providing that an acquisition of the stock or assets of a company…

David S. Miller, Amanda H Nussbaum, Sean M. Webb

“Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

USA - June 29 2020 On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final…

Martine Seiden Agatston, Richard M Corn, Martin T Hamilton, Amanda H Nussbaum, Stuart L Rosow, Christine N. Younger

LIBOR Transition: U.S. Tax Guidance From the IRS

USA - October 15 2019 The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR - relevant to lenders, borrowers and parties to financial…

Martin T Hamilton, Stuart L Rosow, Christine N. Sherman

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption - Limits “Deemed Dividends” for U.S. Corporate Shareholders of CFCs

USA - May 30 2019 Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned…

Richard M Corn, Martin T Hamilton, David S. Miller, Jeremy Naylor, Amanda H Nussbaum

Players, Staff and Draft Picks May be Traded Tax-Free Under New Safe Harbor

USA - April 25 2019 On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports…

Richard M Corn, Amanda H Nussbaum, Jon H. Oram, Alan P Parnes, Christine N. Sherman