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James R. Barry

As seen in: Mondaq
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Articles

Exploring The Unexpected And Often Unwelcome Federal Income Tax Consequences Of Debt Modifications

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By Michelle Jewett, James R. Barry, Russell Nance, Remmelt A. Reigersman
| Mondaq
As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to amend existing debt facilities to extend such maturities as an alternative to refinancing.
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Be Careful What You Wish For: Challenges And Opportunities Arising From The New Unified High-Tax Election

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By James R. Barry, Lucas Giardelli, Michael Lebovitz, Gary Wilcox
| Mondaq
To print this article, all you need is to be registered or login on Mondaq.com. On July 20, 2020, Treasury issued final regulations allowing a high-tax election for global intangible low-taxed income (“GILTI”) purposes and proposed a further set of regulations that would unify that election and the Subpart F high-tax election. This Legal Update discusses some of the key issues and challenges associated with these new final and proposed regulations.
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IRS Issues Proposed Regulations For Calculating UBTI From Separate Unrelated Trades Or Businesses

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By Jeffrey Bruns, Matthew McDonald, James R. Barry, Andre Smith II
| Mondaq
To print this article, all you need is to be registered or login on Mondaq.com. On April 24, the US Internal Revenue Service (the "IRS") issued proposed regulations1 (the "Proposed Regulations"), which clarify how tax-exempt organizations ("exempt organizations") calculate unrelated business taxable income ("UBTI") from separate trades or businesses.
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