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Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

USA - January 14 2019 Aggregate corporations related by 50 common ownership, including foreign corporations to the extent of their effectively connected...

Jared W. Grimley, Elena Romanova, Nicholas J. DeNovio, Michael J. Rowe.


IRS Issues Proposed Regulations on Business Interest Deduction Limitations

USA - December 19 2018 On November 26, 2018, the Treasury and the Internal Revenue Service (IRS) released proposed...

Gregory T. Hannibal, Elena Romanova, Samuel R. Weiner, Lea Li, Chris Ohlgart, Seung Hyun Yang, Joseph M. Kronsnoble, Ana G. O’Brien, Diana S. Doyle, Y. Bora Bozkurt, Eric Cho.


New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate Borrowings

USA - November 5 2018 On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations...

Jocelyn F. Noll, Elena Romanova, Nicholas J. DeNovio, Aaron M. Bernstein, Joseph M. Kronsnoble, Y. Bora Bozkurt.


Tax Reforms Fuel US M&A Activity

USA - June 13 2018 The fundamental US tax reforms brought in this year by the Tax Cuts and Jobs Act (TCJA) have changed the tax landscape for M&A more significantly than...

William Lu.


IRS Previews Upcoming Guidance on Interest Deduction Limitation

USA - April 3 2018 The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations. Key Points:...

Elena Romanova, Y. Bora Bozkurt.