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Proposed Rental Business Safe Harbor under Section 199A
  • Proskauer Rose LLP
  • USA
  • February 7 2019

On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the


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”


IRS Releases Interim Guidance on New Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations
  • Proskauer Rose LLP
  • USA
  • January 14 2019

On December 31, 2018, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2019-09 (the “Notice”)


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


Inclusion of Qualified Transportation Fringe Benefits in UBTI: Guidance, Relief, and Rumors of Possible Repeal
  • Proskauer Rose LLP
  • USA
  • December 19 2018

December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the “Code”), which requires tax-exempt


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


IRS Issues Limited Section 409A Relief to Pay Income Taxes on Pre-2009 Section 457A Deferrals
  • Proskauer Rose LLP
  • USA
  • December 19 2017

The Internal Revenue Service (the “IRS”) has issued Notice 2017-75 (the “Notice”), which provides certain limited relief from the strict requirements


U.S. Tax Reform - Key Highlights for Private Investment Funds in Tax Cuts and Jobs Act Bill
  • Proskauer Rose LLP
  • USA
  • December 18 2017

On Friday, December 15, 2017, the Congressional conference committee released a revised version of the Tax Cuts and Jobs Act (the "Tax Bill"). The


Is It the End of the Johnson Amendment as We Know It?
  • Proskauer Rose LLP
  • USA
  • March 3 2017

While speaking at the National Prayer Breakfast on February 2, 2017, President Trump reaffirmed his commitment to repeal the law that restricts


IRS Updates Ruling Policy on Corporate Business Purpose and Device Requirements under Section 355
  • Proskauer Rose LLP
  • USA
  • August 29 2016

The U.S. Internal Revenue Service (“IRS”) released Revenue Procedure 2016-45 (the “Revenue Procedure”) on August 26, 2016, permitting taxpayers once