Tax Talks

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By: Proskauer Rose LLP

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Mani Kakkar
Richard M. Corn
Amy Drais
Ali Fawaz
Abraham Gutwein
Arnold P. May
Annie Kim
Amanda H. Nussbaum
Tony Oncidi
Alan Parnes
Andrea Rattner
Adam Scoll
Amy Zelcer
Brian Huber
Bowon Koh
Bali Kumar
Colleen Hart
Catherine Sear
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Daniel Rothberg
David S. Miller
Emily Erstling
Elliot Katz
Frank Zarb
Gabriella Ahdoot
Gregory Branagan
Gary Silber
Gary Tashjian
Hank Leibowitz
Ira G. Bogner
Justin Alex
Jamie Bowles
Janicelynn Asamoto Park
Jean Bertrand
James Huffman
Joseph Malca
Jeremy Naylor
Jon Oram
Joshua Miller
Jamiel E. Poindexter
Katrine Berger
Kimberly Ann Condoulis
Kate Napalkova
Kathleen R Semanski
Leslie Loffman
Louis Rambo
Martin T. Hamilton
Michael Fernhoff
Mitchell Gaswirth
Malcolm Hochenberg
Mary B. Kuusisto
Marguerite Lombardo
Martine Seiden Agatston
Michael Sirkin
Rachel Hughes
Robert E. Gaut
Richard Miller
Rebecca Wallis
Steven Einhorn
Sejin Park
Stephen Pevsner
Sara C. Richland
Stuart Rosow
Stephen Severo
Timothy Donovan
Winnie Ma
Jo Habenicht

Latest from Tax Talks

Introduction On October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”)[1] that are likely to allow many controlled foreign corporations (“CFCs”)[2] of U.S. multi-national borrowers to guarantee the debt of their parents and to allow the U.S. parent to pledge more than 66 2/3% of the voting stock of the CFC (and to have the CFC provide negative covenants),…
Posted in Tax
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 designed to encourage investment in distressed communities designated as “qualified opportunity zones” by providing tax incentives to invest in “qualified opportunity funds” (“opportunity funds”) that, in turn, invest directly or indirectly in the opportunity zones. The qualified opportunity zone program generally offers three potential tax benefits to investors: First, a taxpayer…
Posted in Tax
The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were new and surprising. We have summarized here of the most eye-catching changes that will be of interest to our corporate and international client base. Please contact any member of our UK tax group if you have…
Posted in Tax
Welcome to the October edition of the Proskauer UK Tax Round Up. It has been a reasonably busy month, with a number of interesting UK cases being reported as well as further clarity from the CJEU in relation to VAT. The Autumn Budget will be presented later today and the Finance Bill 2019 will be published on 7 November. Please view this month’s issue of the UK Tax Round Up.…
Posted in Tax
On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”), which provides that a repatriation deemed to have been received by a registered investment company (a “RIC”) under Section 965 (enacted as part of the 2017 tax reform act, commonly known as the “Tax Cuts and Jobs Act” or “TCJA”) is treated as a “specified gain.” As a result, the amount of the deemed repatriation need not be distributed…
Posted in Tax
The Internal Revenue Service has published Notice 2018-68 (the “Notice”), which provides long awaited, but limited guidance on the recent amendments to Section 162(m) of the Internal Revenue Code (“Section 162(m)”) by the Tax Cuts and Jobs Act of 2017 (the “TCJA”). Specifically, the Notice provides guidance regarding the identification of a “covered employee” and the grandfathering rules governing written and binding arrangements in effect on November 2, 2017. The Notice applies to any taxable…
Posted in Tax
A number of states have recently proposed or passed new laws related to state-level taxation, some of which are taxpayer-friendly and some of which are expected to impose additional tax burdens on taxpayers. They vary in subject from efforts by states to mitigate the new federal limitation on the deductibility of state and local taxes to proposed changes to state income taxation of “carried interest.” This update reflects some of those recent proposals and laws.…
Posted in Tax
The proposed amendment to entrepreneurs’ relief (“ER”) in Finance Bill 2019 is designed to address one of the outstanding issues with the current law when dilution of a company results in the loss of ER. Under the current rules, a shareholder who has held, for at least 12 months prior to disposal, at least 5% of both the ordinary shares and 5% of the voting rights in a trading company (or holding company of a…
Posted in Tax