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Searching Content indexed under Tax Authorities by Abraham Reshtick ordered by Published Date Descending.
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Overview Of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations
On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the "Tax Act") was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act ...
United States
12 Jan 2018
2
Good News On "Bad Boy" Guarantees; IRS Reverts To Prior Position In Recent Legal Advice Memorandum (ML Tax And Real Estate Alert)
On April 15, 2016, the IRS released a memorandum addressing the impact of so-called "bad boy" guarantees on the characterization of underlying partnership debt as recourse vs. nonrecourse under Section 752 of the Internal Revenue Code.
United States
26 May 2016
3
Good News On "Bad Boy" Guarantees – IRS Reverts To Prior Position In Recent Legal Advice Memorandum
On April 15, 2016, the IRS released a generic legal advice memorandum addressing the impact of so-called "bad boy" guarantees on the characterization of underlying partnership debt as recourse vs. nonrecourse under Section 752...
United States
18 May 2016
4
Is It Debt Or Is It Not? Proposed Treasury Regulations Would Significantly Change Debt Vs. Equity Analysis
Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the "Proposed Regulations") under Section 385 of the Internal Revenue Code.
United States
3 May 2016
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