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US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

USA - March 2 2017 Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business' legal, finance, corporate development and...

Laurence J. Stein, Jared W. Grimley, Sean M. FitzGerald, Patrick Allan Sharma, Michael A. Treska, Joel H. Trotter, Nicholas J. DeNovio, Senet S. Bischoff, Mark D. Gerstein, Thomas H. Halpern, Jiyeon Lee-Lim, Melissa S. Alwang.


Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments

USA - October 26 2016 On October 13, 2016, the US Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) issued final and temporary regulations...

Jared W. Grimley, Jessica J. Chen, Nicholas J. DeNovio, Thomas H. Halpern, Jiyeon Lee-Lim, Enrique Rene de Vera.


IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be Broader

USA - September 23 2016 Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures...

Jared W. Grimley, Sean M. FitzGerald, Nicholas J. DeNovio, Thomas H. Halpern.


Partnerships: IRS Extends Prohibition on Treating Partners as Employees

USA - May 12 2016 Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as "self-employed" for...

Laurence Seymour, David M. Taub, Robin Struve, David O. Kahn, Michael J. Brody.


Congress Permanently Extends Capital Gains Exclusion for Qualified Small Business Stock

USA - December 21 2015 On December 18, 2015, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) into law. The PATH Act retroactively...

Laurence J. Stein, Joseph J. Curran, David O. Kahn.