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IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships With US Assets

USA - January 10 2019 Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partnerâs effectively connected gains or...

Gaston Soler, Cheryl M. Coe.


Qualified Opportunity Funds: Investment and Structuring Considerations

USA - November 7 2018 Investors in qualified opportunity funds may derive significant tax benefits in the form of gain deferral and tax-free appreciation under rules...

Gregory T. Hannibal, Jeesoo Nam, Lea Li, Chris Ohlgart, Ana G. O’Brien.


US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

USA - January 10 2018 On December 22, 2017, President Trump signed into law H.R. 1, informally known as the Tax Cuts and JOBS Act (the Act). The Act, the most comprehensive...

Bryant P. Lee, James H. Cole, Nicholas J. DeNovio, Joseph M. Kronsnoble, C. Timothy Fenn, B. Alan Van Dyke, Jiyeon Lee-Lim, Michael J. Brody, Cheryl M. Coe.


Tax Reform Update Impact on Renewable and Energy Projects

USA - December 20 2017 The conference committee released the final text of its compromise tax reform bill late on Friday. The bill has been passed by both the House and the...

Eli M. Katz, Eric Kamerman, Enrique Rene de Vera.


Impact of the House Tax Reform Bill on the Renewable Energy Sector

USA - November 7 2017 House Republicans unveiled a sweeping tax reform bill on Thursday, November 2 that proposed to lower the corporate tax rate and allow companies to...

Eli M. Katz, Eric Kamerman.