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New 15% Corporate Minimum Tax: Short Summary and Potential Impact on Mergers and Acquisitions

USA - August 15 2022 On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022, HR 5376 (the Act), which imposes a new 15% corporate minimum tax on…

Eric M. Grosshandler, Rachel D. Kleinberg, Jonathan M. Westreich

New 1% Excise Tax on Stock Repurchases by Publicly Traded Corporations

USA - August 15 2022 On August 12, 2022, the U.S. Congress voted to pass the Inflation Reduction Act of 2022, HR 5376 (the Act), which includes a new 1% Excise tax on…

Eric M. Grosshandler, Rachel D. Kleinberg, Jonathan M. Westreich

Final and Proposed PFIC Regulations Provide Further Guidance for Non-U.S. Insurance Companies and Their U.S. Investors

USA - December 7 2020 On December 4, 2020, the U.S. Internal Revenue Service and Department of the Treasury released final and proposed regulations relating to passive…

Daniel Altman, Laura M. Barzilai, Tracy D.Williams, Joseph M. Paral

COVID-19: IRS Provides Temporary Liquidity Relief to Real Estate Investment Trusts and Regulated Investment Companies

USA - May 7 2020 The U.S. Internal Revenue Service (IRS) has temporarily reduced the percentage of a combined distribution of cash and stock by a public real estate…

Dustin R. Anderson, Ivy H. Jones

The Midstream Energy REIT: Has Its Time (Finally) Come?

USA - November 19 2019 The market for midstream energy master limited partnerships (MLPs) (approximately $250B market capitalization at the end of September 2019) has…

Angela T. Richards