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Treasury Issues Further Guidance on Bonus Depreciation Rules, Declines to Amend Legislative Drafting Glitch

USA - September 19 2019 On September 13, 2019, the Treasury Department issued final and proposed regulations providing guidance on the 100% bonus depreciation rules under…

Joseph Opich, Kami LaBerge, Michael D. Haun.

Depreciation of Tenant Improvements After Tax Reform: Confusion Reigns

USA - March 23 2018 On December 22, 2017, the President signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “New Act”). The New Act was…

Amy L. Lawrence.

Section 355 Spin-Off Developments: Clarification of “Predecessors” and “Successors”

USA - January 12 2017 Despite the numerous and complex requirements associated with a valid Section 355 spin-off a qualifying distribution under Section 355 is one of the…

Erika Mayshar.

Victory for out-of-state members in LLCs doing business in California

USA - December 2 2014 The California Franchise Tax Board ("FTB") has taken an increasingly aggressive stance in recent years regarding its ability to tax out-of-state…

Erika Mayshar.

Section 336(e): final regulations related to deemed asset purchases provide new flexibility in structuring acquisitions

USA - May 23 2013 The Internal Revenue Service has recently issued final regulations implementing Section 336(e) of the Internal Revenue Code (the "Final Regulations")…

Alexander M. Lee, Ziemowit T. Smulkowski.