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Taxpayer Expectations: Legitimate or Not?

United Kingdom - December 11 2019 The Court of Appeal in The Queen (on the application of Aozora GMAC Investment Limited) v HMRC 2019 EWCA Civ 1643 (Aozora) recently upheld the...

Linda Z. Swartz, Mark P. Howe, Jason Schwartz, Adam Blakemore.

IBOR Transition Update: The Fair Market Value Test

United Kingdom - December 11 2019 In October, Treasury and the IRS issued proposed regulations confirming that switching from a LIBOR-based rate to a SOFR-based rate in a debt...

Linda Z. Swartz, Mark P. Howe, Jason Schwartz, Adam Blakemore.

IRS Proposes Narrowing Debt Recast Rules

USA - December 11 2019 Regulations issued in 2016 treat a putative debt instrument as equity if, among other things, (1) the instrument is issued to a person related to the...

Linda Z. Swartz, Mark P. Howe, Jason Schwartz, Adam Blakemore.

Close Your Eyes: Additional Thoughts on CFC Downward Attribution

USA - December 11 2019 Under the controlled foreign corporation (CFC) rules of the tax code, taxpayers may be subject to adverse tax consequences, including "phantom...

Linda Z. Swartz, Mark P. Howe, Jason Schwartz, Adam Blakemore.

Guidance on Crypto Hard Forks and Airdrops

USA - December 11 2019 On October 9, the IRS issued Revenue Ruling 2019-24, which addresses the tax treatment of cryptocurrency hard forks and airdrops. Very generally, a...

Linda Z. Swartz, Mark P. Howe, Jason Schwartz, Adam Blakemore.