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Certain Senior Living Facilities Can Elect Out of the Business Interest Limitation

USA - February 2 2021 On December 29, 2020, the Internal Revenue Service issued Revenue Procedure 2021-9 (the “Procedure”), which provides a safe harbor…

Michael Lobie, Cynthia J. Mitchell

UBIT May Be In Your Future

USA - November 3 2017 The proposed Tax Cuts and JOBS Act released by the House of Representatives on November 2, 2017 calls into question the position long taken by…

Robert L. Bodansky, Stanley S. Jutkowitz

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

USA - November 3 2016 On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final…

Steven R. Meier

There is life after death...of the Bottom-Dollar Guarantee

USA - October 14 2016 On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other…

Steven R. Meier, John P. Napoli, Michael Rosenthal