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Articles by Devon Bodoh
Oecd Inclusive Framework Reaches Agreement On Pillar Two "Side-By-Side" Package
Devon Bodoh’s articles from Weil, Gotshal & Manges LLP are most popular: within Tax topic(s) with Finance and Tax Executives in United States with readers working within the Accounting & Consultancy and Business & Consumer Services industries The year has begun with important developments in the international tax landscape, as countries participating in the OECD Inclusive Framework reached agreement on a package of measures reshaping the operation of Pillar Two (the Global Anti-Base Erosion,...
IRS Issues Final And Proposed Regulations Clarifying Section 892 Exemption For Foreign Government Investors
WG Weil, Gotshal & Manges LLP More Founded in 1931, Weil has provided legal services to the largest public companies, private equity firms and financial institutions for more than 90 years. Widely recognized by those covering the legal profession, Weil’s lawyers regularly advise clients globally on their most complex Litigation, Corporate, Restructuring, and Tax, Executive Compensation & Benefits matters.
Devon M. Bodoh | Weil, Gotshal & Manges LLP | ICLG
Devon M. Bodoh is a Partner in Weil’s Tax Department and is based in Washington, D.C. Mr. Bodoh is the head of the Firm’s M&A Tax practice and International and Cross-border Tax practice, a member of the Tax Department’s leadership team, and Co-Managing Partner of the Miami office.
Trump Tax Law's Most Impactful Energy Changes
By Devon Bodoh, Joseph Pari and Steven Lorch ( September 2, 2025, 5:36 PM EDT) -- On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This three-part article explores the transformative impact the bill may have on U.S. international, corporate and individual tax policy, highlighting key provisions, permanent extensions of various tax breaks, and the potential implications for taxpayers and industries.... Law360 is on it, so you are, too.
Trump Tax Law's Most Impactful Energy Changes
On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This three-part article explores the transformative impact the bill may have on... To view the full article, register now.
Trump Tax Law's Most Impactful Energy Changes - Law360
By Devon Bodoh, Joseph Pari and Steven Lorch ( September 2, 2025, 5:36 PM EDT) -- On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This three-part article explores the transformative impact the bill may have on U.S. international, corporate and individual tax policy, highlighting key provisions, permanent extensions of various tax breaks, and the potential implications for taxpayers and industries....
Trump Tax Law's Most Impactful Corp. And Individual Changes
On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This two-part article explores the transformative impact the bill may have on... To view the full article, register now.
Trump Tax Law's Most Impactful Corp. And Individual Changes
By Devon Bodoh, Joseph Pari and Steven Lorch ( August 26, 2025, 4:53 PM EDT) -- On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This two-part article explores the transformative impact the bill may have on U.S. international, corporate and individual tax policy, highlighting key provisions, permanent extensions of various tax breaks, and the potential implications for taxpayers and industries.... Law360 is on it, so you are, too.
Trump Tax Law's Most Consequential International Changes
On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This two-part article explores the transformative impact the bill may have on... To view the full article, register now.
Trump Tax Law's Most Consequential International Changes
By Devon Bodoh, Joseph Pari and Steven Lorch ( August 25, 2025, 5:08 PM EDT) -- On July 4, President Donald Trump signed the One Big Beautiful Bill Act, a sweeping tax and spending package. This two-part article explores the transformative impact the bill may have on U.S. international, corporate and individual tax policy, highlighting key provisions, permanent extensions of various tax breaks, and the potential implications for taxpayers and industries.... Law360 is on it, so you are, too.
The One, Big, Beautiful Bill Act: The Future Of Tax Policy?
After much debate on Capitol Hill, President Trump signed into law the One, Big, Beautiful Bill Act (the "Bill") on July 4, 2025, delivering a sweeping legislative tax and spending package. The House of Representatives voted to approve its version of the Bill on May 22, 2025 (the "House Bill"), and the Senate voted to approve a modified version of the Bill on July 1, 2025 (the "Senate Bill").
Tax Executive Orders and Proposals Released by the US President
Click here to listen to the audio. In the latest episode of the Weil Tax Insight series, Tax Co-Chair Joe Pari and International Tax Head Devon Bodoh highlight executive orders issued by President Trump’s administration, along with various tax proposals referenced both before and after the election.
Devon M. Bodoh | Weil, Gotshal & Manges LLP | ICLG
ICLG News Weil takes Akin tax partner The firm has bolstered its tax capabilities in New York, welcoming a lawyer with almost two decades of experience. Ella Fincken | 26 June, 2025 ICLG News Weil scores with entertainment, sports and media expert hire The latest hire is a prominent entertainment, sports and media dealmaker and his arrival follows the appointment of partner Steve Argeris, both of whom will help boost the firm’s West Coast presence.
New IRS Guidance on Spin-Offs and CAMT: Expert Analysis
USA October 15 2024 Click here to listen to the audio. In the latest edition of the Weil, Gotshal & Manges Expert Focus series on US tax issues, the firm’s tax co-chair Joe Pari and international tax head Devon Bodoh discuss recent guidance on the procedural mechanisms for obtaining an IRS ruling with respect to a tax-free spin-off, covering both substance and procedure related to this guidance, as well as the long-awaited guidance on corporate alternative minimum tax.
Treasury and IRS issue final rules relating to repatriation of IP
On October 9, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”), which, in certain cases, terminate the continued application of Section 367(d) of the Internal Revenue Code (the “Code”) from a previous transfer of intangible property to a foreign corporation when the intangible property is repatriated to certain U.S. persons. Background.
Treasury and IRS Issue Long Awaited Proposed Regulations on the Corporate Alternative Minimum Tax
On September 12, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG 112129-23, RIN 1545-BQ84) (the “Proposed Regulations”) providing much needed guidance on the application of the corporate alternative minimum tax (“CAMT”).
New IRS Proposed Regulations Address Dual Consolidated Loss Rules
On August 6, 2024, the Treasury Department (“Treasury”) issued Proposed Regulations (REG- 102144-04) (the “Proposed Regulations”) regarding section 1503(d) of the Internal Revenue Code.
Easy as ABC - IRS Issues Final Rules Aimed at Stymieing Killer Bs
On July 17, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations under Section 367(b) of the Internal Revenue Code (the “Code”) that provide guidance applicable to: the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to those reorganizations; and...
Final Regulations: Guidance on Reporting and Payment of Excise Tax
On June 28, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (T.D. 10002) (the “Final Regulations”) that provide guidance applicable to the reporting and payment of the excise tax under section 4501 of the Internal Revenue Code of 1986, as amended (the “Code”), on repurchases of corporate stock after December 31, 2022 (the “Excise Tax”) The Final Regulations adopt, without significant modification, one set of proposed...
Clear as Mud - Chevron Irreverence and Tax Law
In a 6-3 decision written by Chief Justice Roberts, the Supreme Court in Loper Bright Enterprises v. Raimondo overturned the Court’s decision in Chevron v.
Devon Bodoh Participates in the Taxation of Cross-Border Transactions: Section 367 Panel
USA June 20 2024 Click here to watch the video. Devon Bodoh participated in the Taxation of Cross-Border Transactions: Section 367 panel at the American Enterprise Institute Panel, where the discussion focused on how the 2017 Tax Cuts and Jobs Act introduced the most significant changes to US international tax rules in almost a century. These changes were built on an already-complex tax system, and in 2026, some of the most important rate provisions are set to increase.
Crypto Broker Reporting Regulations Should Avoid Mismatch Risk
The IRS’s April 19 release of the draft Form 1099-DA—which will be used to report certain sales and exchanges of digital assets on or after Jan. 1, 2025—may indicate that the IRS is close to finalizing proposed regulations extending information-reporting rules under tax code Section 6045 to crypto and other digital asset transactions.
Updated Procedures for Section 355 Private Letter Rulings: Rev. Proc. 2024-24 and Notice 2024-38
On May 1, 2024, the Treasury Department and Internal Revenue Service (the “Treasury” and “IRS,” respectively) issued Revenue Procedure (“Rev. Proc.”) 2024-24 and Notice 2024-38 (collectively, the “Guidance”). The Rev. Proc.
IRS Issues Final Regulations for Foreign Investment in Qualified Investment Entities (REITS and RICS)
Overview On April 24, 2024, the Internal Revenue Service (“IRS”) and Treasury Department issued final regulations (T.D. 9992) under section 897 of the Internal Revenue Code of 1986, as amended (the “Code,” and such final regulations, the “Final Regulations”) detailing, among other things, whether a qualified investment entity (“QIE”) is domestically controlled for purposes of section 897(h)(2) of the Code (the “DC-QIE Exception”), and providing much needed clarification regarding the proper...
Here We Go - Excise Tax Proposed Regulations Largely “NSYNC” with Notice 2023-2
On April 9, 2024, the Treasury Department (the “Treasury”) and Internal Revenue Service (the “IRS”) two sets of proposed regulations (the “Proposed Regulations”) regarding the application of the section 4501 excise tax on repurchases of corporate stock (the “Excise Tax”) and the reporting and payment of such taxes. The Proposed Regulations generally follow the approach of Notice 2023-2 (the “Notice”), which was issued on Dec. 27, 2022, with some clarifications and modifications.
Examining the U.S. - Chile Tax Treaty
Introduction On December 19, 2023, the United States Department of the Treasury announced the entry into force of the tax treaty between the United States and Chile (the “Treaty”). Originally signed by the United States and Chile on February 4, 2010, the Treaty was approved by Chilean government in 2015 and was ratified by the United States Senate (subject to two reservations incorporated into the Treaty, discussed below) and signed by President Biden on June 22, 2023.
IRS Releases Guidance to Clarify Corporate AMT Calculations
The Inflation Reduction Act of 2022 (“IRA”) introduced a corporate alternative minimum tax (“CAMT”) on an “applicable corporation’s” (“Applicable Corporation”) financial statement income. The CAMT is applicable for taxable years beginning after December 31, 2022 and imposes a 15% minimum tax on a corporation’s “applicable financial statement income” (“AFSI”).
IRS Issues Guidance on Foreign Tax Credit and Global Minimum Tax
On December 11, 2023, the Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”) establishing the intentions of the Treasury Department (“Treasury”) and the IRS to issue proposed regulations addressing the application of the foreign tax credit (“FTC”) rules and dual consolidated loss (“DCL”) rules with respect to certain taxes under the Pillar Two global anti-base erosion (“GloBE”) rules.
Killer Bs Get Stung - IRS Issues Proposed Rules Aimed at Triangular Reorganizations and Inbound Non-recognition Transactions
On October 5, 2023, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued long awaited proposed regulations under Section 367(b) of the Internal Revenue Code (the “Code”) providing guidance on the use of property to acquire parent stock or securities in connection with certain cross border triangular reorganizations, colloquially referred to as ‘Killer B’ transactions (the “Proposed Regulations”).
IP Phone Home - IRS Issues New Proposed Rules on the Repatriation of Intangible Property
Section 367(d) of the Internal Revenue Code (the “Code”) provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation.
State of the Union: President Biden Calls for Increase to the Excise Tax
The Inflation Reduction Act of 2022 imposes a one percent excise tax (the “Excise Tax”) on the repurchase of corporate stock under Section 4501 of the Internal Revenue Code (“Section 4501” and the “Code”, respectively) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. Much welcome guidance was released on December 27, 2022 in Notice 2023-2 (the “Notice”), which provides taxpayers with interim guidance until proposed regulations are issued.
Notice 2023-7 Provides Guidance for Applying Corporate Alternative Minimum Tax
The Inflation Reduction Act of 2022 (“IRA”) introduced a corporate alternative minimum tax (“CAMT”) on an “applicable corporation’s” (“Applicable Corporation”) financial statement income. The CAMT is applicable for taxable years beginning after December 31, 2022 and imposes a 15% minimum tax on a corporation’s “applicable financial statement income” (“AFSI”).
Practical PFIC Considerations in Connection with SPACs | JD Supra
A number of practical considerations must be taken into account in connection with the formation and operation of a non-U.S. special purpose acquisition company (“SPAC”) to mitigate the potential risk of the non-U.S. SPAC being treated as a passive foreign investment company (“PFIC”) for U.S. federal income tax purposes.
The Treasury Department Releases Final and Proposed PFIC Regulations | JD Supra
[co-author: Kerri Gallagher] On December 4, 2020, the IRS released final regulations (T.D. 9936) and proposed regulations (REG-111950-20) relating to the modification of the passive foreign investment company (PFIC) rules. These regulations contain rules for determining when a foreign corporation is classified as a PFIC and whether a U.S. person indirectly holding stock in a PFIC is treated as a shareholder of that PFIC.
Brexit & Tax Treaties: U.K. Investors May Lose Treaty Benefits With Respect to U.S. Investments | JD Supra
The withdrawal of the United Kingdom (“U.K.”) from the European Union (“E.U.”) may impact certain cross-border organizational structures. We have previously considered some of those U.K. tax impacts in our post “Brexit and Tax: An Uncertain Future”.
Final Section 864(c)(8) Regulations – Some Relief for Certain Non-U.S. Partners | JD Supra
On September 21, 2020, the IRS finalized regulations (the “Final Regulations”) under section 864(c)(8) of the Internal Revenue Code (the “Code”). The Final Regulations generally impact foreign partners in partnerships engaged in a U.S. trade or business and generally retain the approach of proposed regulations that were issued on December 20, 2018 (REG-113604-08) (the “Proposed Regulations”), with certain revisions.
Relief From the Repeal of Section 958(b)(4) Downward Attribution | JD Supra
On September 21, 2020, the IRS released for publication final regulations (T.D. 9908) relating to the modification of section 958(b) by the Tax Cuts and Jobs Act (“TCJA”). These regulations affect U.S. persons that have ownership interest in, or that make or receive payments to or from, certain foreign corporations. By way of background, section 958(b)(4) prevented “downward attribution” of stock owned by a foreign person to a U.S. person.
Final Debt/Equity Regulations | JD Supra
On May 13, 2020, the IRS finalized the “debt/equity” regulations under Section 385 by publishing T.D. 9897. These final regulations implement the 2016 proposed regulations1 (the “2016 Proposed Regulations”) that cross referenced temporary regulations2 (the “2016 Temporary Regulations”) issued in 2016. There were no substantive changes in the final regulations from the 2016 Proposed Regulations or the 2016 Temporary Regulations.
COVID-19 – Benefiting from Worthless Stock Losses | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Guidance on Certain Net Operating Loss Elections Under the CARES Act | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Anti-Hybrid Rules: The IRS Issues Final & Proposed Regulations | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
The CARES Act: A Guide to the Tax Provisions | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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