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1
Applying Acquisition Price Method To Post-TCJA Platform Contribution Transactions
Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.
United States
13 Aug 2019
2
Capital Markets Tax Quarterly - Volume 2, Issue 2
Q2 2019 started out with a great deal of hope in the world of capital markets taxation.
United States
6 Aug 2019
3
Final Regulations Published Addressing Income Inclusion Rules For Pass-Through Lease Of ITC Property
On July 17, 2019, the US Internal Revenue Service issued final regulations (T.D. 9872) providing guidance on the rules under Internal Revenue Code section 50(d)(5) requiring an income inclusion by the lessee ...
United States
29 Jul 2019
4
IRS Releases 2019 Section 45 Production Tax Credit Amounts
On June 6, 2019, the US Internal Revenue Service (IRS) published a notice providing the inflation-adjustment factors and reference prices for the calculation of renewable electricity PTCs under IRC section 45 for 2019.
United States
25 Jul 2019
5
IRS Issues Proposed Regulations Regarding Withholding Under Section 1446(f)
On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)
United States
15 Jul 2019
6
Rare Supremacy Clause Tax Win For P.L. 86-272 Company
In a rare challenge involving the US Constitution's Supremacy Clause, Mayer Brown lawyers successfully argued that New Jersey's Corporate Business Tax alternative minimum assessment has been unconstitutional since 2006.
United States
12 Jul 2019
7
How To Structure A Tax-Efficient IPO: Benefits Of The Up-C Structure
A partnership (or LLC) can go public in a highly tax-efficient manner by using an "Up-C" structure. An Up-C structure is composed of two entities: (1) a parent company,
United States
30 May 2019
8
The Up-C Structure In IPOs
The umbrella partnership - C corporation structure ("Up-C") is an indirect mode for an operating partnership to conduct an initial public offering ("IPO").
United States
29 May 2019
9
Legal Update: Section 956's "Deemed Dividend" Rules: An Update For Lenders On Proposed Changes
Section 956 of the US Internal Revenue Code ("Section 956") has historically loomed large in the context of finance transactions because it limited the ability of US borrowers to use overseas assets
United States
23 Apr 2019
10
Maryland's Energy Storage Tax Credit Turns Two
As previously discussed on this blog, Maryland, in 2017, become the first state in the county to offer an income tax credit for energy storage systems and, to our knowledge,
United States
15 Apr 2019
11
Cadillac Tax Repeal On The Horizon?
The Affordable Care Act contains a provision–the so-called "Cadillac tax"–providing for a 40% exciClassic Cadillacse tax on high cost employer-sponsored health coverage.
United States
21 Mar 2019
12
Infocast's Wind Finance & Investment Summit Soundbites
Below are soundbites from panelists who spoke at Infocast's Wind Finance & Investment Summit on February 6 and 7 in Carlsbad, CA.
United States
8 Mar 2019
13
Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
14
IRS Issues Proposed Regulations Implementing Base Erosion Anti-Abuse Tax (BEAT) Rules
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
28 Jan 2019
15
The Public-Private Partnership Infrastructure Exception To The Internal Revenue Code Section 163(J) Interest Deduction Limitation
On November 26, 2018, the US IRS released an advance version of Revenue Procedure 2018-59, which would allow taxpayers providing certain infrastructure-related services in public-private partnerships to avoid...
United States
28 Jan 2019
16
BEATen Up (Again): The IRS Issues Proposed Regulations Under The Base Erosion Anti-Abuse Tax
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
25 Jan 2019
17
Treasury Adds Color To Grecian Repeal – Proposed Regulations Implement New Section 864(C)(8) For Sale Of Partnership Interests By Foreign Partners
On December 20, 2018, the US Department of Treasury and the IRS released proposed regulations under Section 864(c)(8) of the Code on the treatment of a foreign partner's transfer of an interest in a partnership...
United States
14 Jan 2019
18
IRS Releases Proposed Anti-Hybrid Regulations
The US Tax Cuts and Jobs Act of 2017 added new sections 245A(e) and 267A to the Code. Section 245A(e) denies the section 245A dividends-received deduction for "hybrid" dividends.
United States
8 Jan 2019
19
Solar Power International 2018: Soundbites
Below are soundbites from panel discussions at Solar Power International on September 25 and 26 in Anaheim, California.
United States
4 Jan 2019
20
Supreme Court To Decide Whether Punitive Damages May Be Awarded In Connection With Unseaworthiness Claims
When the Supreme Court agrees to hear a punitive damages case, that's always news
United States
3 Jan 2019
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