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Cancellation of indebtedness income: Beware of hidden tax costs in debt modifications

USA - May 28 2020 The global COVID-19 pandemic has created financial distress for businesses across the United States, many of which may have been forced to close or…

Frank Comparetto III, David A. Roby, Jr., Taylor M. Kiessig, Wes Sheumaker

Relief for REMICs addressing phaseout of LIBOR

USA - October 11 2019 New proposed regulations provide guidelines for alterations to Certain Interests in real estate mortgage investment conduits (REMICs) and loans held…

Aaron M. Payne, Robert S. Chase II, Taylor M. Kiessig, Mary E. Monahan, Caroline R. Reaves

No longer up in the air? Cloud transaction regulations are released

USA - August 21 2019 Long-awaited proposed regulations recently released by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) address the…

Robert S. Chase II, Caroline R. Reaves, Carol P. Tello, H. Karl Zeswitz

Fine-tuning the course—Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions

USA - May 30 2019 On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final…

Aaron M. Payne, Randy Buchanan, Amanda P. Cooper, Robert S. Chase II, Hyowon Lee, Carol P. Tello

Spinning in circles, Treasury resumes original course on regulated investment company income rules

USA - March 25 2019 On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations)…

Michael R. Miles, Robert S. Chase II, David A. Roby, Jr., Daniel R. McKeithen, Rich Sun, H. Karl Zeswitz