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Results:1-10 of 52

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
  • Proskauer Rose LLP
  • USA, OECD
  • January 25 2019

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid”


The Proposed BEAT Regulations
  • Proskauer Rose LLP
  • USA
  • December 31 2018

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the


FATCA: Significant Relief in New Proposed Regulations
  • Proskauer Rose LLP
  • USA
  • December 17 2018

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations


U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations
  • Proskauer Rose LLP
  • USA
  • December 5 2018

On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations


Impact of Proposed Regulations under Section 956 on Lending Arrangements Involving U.S. Corporate Borrowers
  • Proskauer Rose LLP
  • USA
  • November 13 2018

On October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed


Summary of the Opportunity Zone Program
  • Proskauer Rose LLP
  • USA
  • November 8 2018

The Tax Cuts and JOBS Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program. The program is


New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs
  • Proskauer Rose LLP
  • USA
  • September 21 2018

On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation


Digital Economy: Supreme Court Overturns Physical Presence Requirement for State Sales Tax
  • Proskauer Rose LLP
  • USA
  • June 26 2018

In a landmark decision changing course on decades of precedent, the United States Supreme Court decided on June 21, 2018 South Dakota v. Wayfair, Inc


Tax Reform - I.R.S. Updates Withholding Tax Guidance on Sales of Partnership Interests
  • Proskauer Rose LLP
  • USA
  • May 9 2018

On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-291 (the “Notice”), announcing the intention of the IRS and the


Impact of Recent Tax Legislation on M&A Transactions
  • Proskauer Rose LLP
  • USA
  • February 9 2018

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect