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Searching Content indexed under Income Tax by Kramer Levin Naftalis & Frankel LLP ordered by Published Date Descending.
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Qualified Opportunity Fund Investments: Important Deadlines
The Qualified Opportunity Zone (QOZ) tax incentive program provides an opportunity for a taxpayer to defer and potentially eliminate the recognition of capital gains if,
United States
8 Jul 2019
2
Final Treasury Regulations Facilitate Foreign Subsidiary Credit Support
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code).
United States
18 Jun 2019
3
How The SEC's Proposed Amendments To Financial Disclosures For Acquisitions Will Affect High-Yield Bond Offerings
On May 3, the Securities and Exchange Commission (the SEC) proposed amendments to its rules governing financial disclosures relating to acquisitions and dispositions of businesses.
United States
30 May 2019
4
IRS Paves The Way For Lenders To Obtain Guarantees And Collateral From (And 100% Stock Pledges Of) Foreign Subsidiaries
Absent the applicability of the proposed regulations, such credit support generally would result in a taxable "deemed dividend" to the U.S. parent corporation borrower.
United States
20 Nov 2018
5
Tax Reform Act Changes To CFC Attribution Rules
The recently enacted tax reform act significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct dividends received from...
United States
5 Apr 2018
6
REITs And Their Shareholders Stand To Gain Under New Tax Law
In their article "REITs and Their Shareholders Stand to Gain Under New Tax Law," which appeared in the March 2, 2018, issue of Commercial Observer, Tax partner Barry Herzog and associate Rita Celebrezze D'Souza...
United States
14 Mar 2018
7
Impact Of The Tax Law On Estate Planning
President Trump signed sweeping tax legislation into law on Dec. 22, 2017, resulting in several significant changes to the wealth transfer tax system, effective as of Jan. 1, 2018.
United States
4 Jan 2018
8
Tax Reform
On Dec. 22, 2017, President Trump signed into law tax reform legislation ("the Act") that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal Revenue Code of 1986, as amended ("the Code"), which likely will significantly affect many of our clients:
United States
3 Jan 2018
9
The Limitations On Interest Deductibility In The New Tax Law
The Senate passed the same legislation earlier in the day.
United States
27 Dec 2017
10
Tax Reform Bills Seek Largest Restructuring Of Tax Code In More Than A Generation
On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act.
United States
4 Dec 2017
11
Tax Reform In The New Administration
The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system...
United States
9 Jan 2017
12
Debt Dialogue: November 2016
This month's issue of Debt Dialogue address developments in areas of debt, taxation, settlement cycles for securities and bank debt and securities law enforcement for muni debt.
United States
21 Nov 2016
13
Reporting Requirements Under French Law For Trusts With Connections To France
French legislation enacted in 2011 imposed reporting requirements on trustees and changed the treatment of trusts for purposes of income, gift, succession and wealth tax, and established a new special trust tax.
France
11 Jul 2016
14
New Treasury Regulations Make Inversions More Difficult And Alter The Treatment Of Debt Instruments Between Related Companies
Corporate inversions have been at the forefront of discussions regarding international tax reform.
United States
16 May 2016
15
New York State Takes On Carried Interest Reform
Carried interest has been at the forefront of tax reform proposals in recent years. Carried interest refers to the share of profits that many fund managers receive from managing fund capital.
United States
8 Apr 2016
16
New Legislation Affects The Taxation Of Foreign Investments In U.S. Real Estate
The Protecting Americans from Tax Hikes Act of 2015 (the "Act") became law on Dec. 18, 2015.
United States
11 Mar 2016
17
Dividend Equivalent Payments — Final And Temporary Regulations Issued
On Sept. 18, 2015, the IRS issued final regulations governing "dividend equivalent" payments made to foreign persons.
United States
5 Oct 2015
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