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Articles by Jay Singer
Treasury and IRS relax proposed regulations regarding tax-free spin-offs
On October 21, 2026, the Department of the Treasury and the Internal Revenue Service (the "IRS") published guidance (the "Notice of Withdrawal") partially withdrawing the proposed regulations under section 355 concerning the device prohibition and the active trade or business requirement that were published on July 15, 2016 (REG-134016-15, 81 FR 46004) (the "2016 Proposed Regulations").
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
Hogan Lovells Cadwalader are most popular: within Intellectual Property, Government, Public Sector, Food, Drugs, Healthcare and Life Sciences topic(s) with readers working within the Consumer Industries industries On August 26, the Treasury Department published proposed regulations (the “Proposed Regulations”) under Code sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of subpart F income, tested income, and tested loss of a controlled foreign...
ABA 2026 May Tax Meeting
Partner Lauren Clarke will participate in “REIT PLR Updates,” a panel to discuss significant REIT PLR updates over the last year including airports, cold storage, EV charging, and consent dividends. Partner David Olstein will participate in three panels or plenaries: Plan Investments & Products: A Brave New World: The panelists will address the evolving landscape of plan investment and products being used and introduced for 401(k) plans.
Hogan Lovells advises Bell Partners on acquisition by Sun Life Financial
The transaction is expected to close in the second half of 2026, subject to receipt of regulatory and Toronto Stock Exchange approvals and satisfaction of customary closing conditions. Upon closing, the combined global real estate business of BGO and Bell Partners will represent more than US$100 billion of assets under management. More information on the transaction can be found here.
Final Regulations on the Section 4501 Excise Tax on the Repurchase of Corporate Stock | JD Supra
[co-author: Kelsey Levin-Epstein] On November 24, 2025, the IRS published final regulations (the “Final Regulations”) providing comprehensive guidance on the application of the excise tax on repurchases of corporate stock under Section 4501, as enacted by the Inflation Reduction Act of 2022 (the “Stock Repurchase Excise Tax”).
Final regulations on the Section 4501 excise tax on the repurchase of corporate stock
On November 24, 2025, the IRS published final regulations (the “Final Regulations”) providing comprehensive guidance on the application of the excise tax on repurchases of corporate stock under Section 4501, as enacted by the Inflation Reduction Act of 2022 (the “Stock Repurchase Excise Tax”).
IRS reduces barriers to redomiciliations | JD Supra
On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded corporations to the United States by limiting the circumstances in which certain provisions of the Foreign Investment in Real Property Tax Act (“FIRPTA”) would tax such transactions.
New Section 899 – Enforcement of remedies against unfair taxes | JD Supra
On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the undertaxed profits rule (“UTPR”) currently adopted by 30 members of the OECD as a part of its Pillar 2 global minimum tax regime.
New Section 899 - Enforcement of remedies against unfair taxes
Summary On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the undertaxed profits rule (“UTPR”) currently adopted by over 25 members of the OECD as a part of its Pillar 2 global minimum tax regime. Section 899 would increase US tax rates imposed on applicable tax residents of countries that have adopted such unfair taxes.
Shearman & Sterling LLP
CONTRIBUTING SINCE APRIL 2002 Our success is built on our clients’ success. We have a long and distinguished history of supporting our clients wherever they do business, from major financial centers to emerging and growth markets. We represent many of the world’s leading corporations and major financial institutions, as well as emerging growth companies, governments and state-owned enterprises, often working on ground-breaking, precedent-setting matters.
Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax liabilities
On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503[1] (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the Global Anti-Base Erosion Rules (Pillar Two) (“Pillar Two Rules”),[2] among other DCL issues.[3] If finalized, the Proposed Regulations would increase the relevance of the DCL rules for many U.S. consolidated groups with foreign affiliates either above or below such U.S....
U.S.-Chile Income Tax Treaty Enters Into Force
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On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”).[1] The Treaty provides for reduced withholding tax rates on income such as dividends, interest and royalties with the goal of reducing double taxation and increasing commerce and investment between the United States and Chile.
By Larry Crouch, Ryan Bray, Todd Lowther, Jay Singer, Matthew Brown Verified, José Germano Rego, José Márcio Rêgo
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Lexology
Verified
Funding rule under notice 2023-2 expands the scope of the stock buyback excise tax to repurchases of stock of many foreign corporations
Notice 2023-2[1] (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise Tax”) imposed by section 4501 of the Internal Revenue Code of 1986, as amended (the “Code”).[2] Although section 4501 on its surface primarily applies to publicly traded domestic corporations, the Notice contains a “per se” funding rule that appears to cause the Excise...
Highly Anticipated Covid Relief Legislation Contains Numerous Tax Provisions
To print this article, all you need is to be registered or login on Mondaq.com. On December 27, 2020, President Trump signed into law The Consolidated Appropriations Act, 2021 (the CAA).
Highly anticipated covid relief legislation contains numerous tax provisions | Lexology
On December 27, 2020, President Trump signed into law The Consolidated Appropriations Act, 2021 (the CAA).
IRS and Treasury Issue Final Regulations Regarding Use of Consolidated Net Operating Losses | JD Supra
On October 13, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the “Regulations”) under sections 1502 and 1503 of the Internal Revenue Code of 1986, as amended (the “Code”),[1] regarding the absorption of consolidated net operating losses (CNOLs) carryovers applicable to consolidated groups that include one or more nonlife insurance company members and one or more life insurance and/or non-insurance company...
IRS And Treasury Issue Final Regulations Regarding Use Of Consolidated Net Operating Losses
To print this article, all you need is to be registered or login on Mondaq.com.
Final BEAT Deduction Waiver Regulations Provide Some Relief | JD Supra
On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the “Regulations”) permitting taxpayers to waive deductions to reduce or eliminate liability for the base erosion and anti-abuse tax (generally referred to as the “BEAT”). The BEAT was introduced as part of the Tax Cuts and Jobs Act of 2017 to prevent U.S. corporations from unduly reducing their U.S. taxable income through payments to related foreign parties.
Final Beat Deduction Waiver Regulations Provide Some Relief
To print this article, all you need is to be registered or login on Mondaq.com. On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the "Regulations") permitting taxpayers to waive deductions to reduce or eliminate liability for the base erosion and anti-abuse tax (generally referred to as the "BEAT").
Tax Planning After The GILTI And Subpart F High-Tax Exceptions
To print this article, all you need is to be registered or login on Mondaq.com. On July 23, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9902) with respect to the global intangible low-taxed income (GILTI) high-tax exception (“Final Regulations”). The Final Regulations largely finalize regulations previously proposed on June 14, 2019 (GILTI Proposed Regulations) with some significant changes as described below.
Irs Issues Guidance On Interaction Of Net Operating Loss And Alternative Minimum Tax Rules
To print this article, all you need is to be registered or login on Mondaq.com. On May 27, 2020, the U.S. Internal Revenue Service (the IRS) published guidance (the Guidance) regarding the interaction of the five-year net operating loss (NOL) carryback rules under the Coronavirus Aid, Relief and Economic Security Act (the CARES Act) and the corporate alternative minimum tax (the AMT).
IRS Announces That Expenses Giving Rise To PPP Loan Forgiveness Cannot Be Deducted
To print this article, all you need is to be registered or login on Mondaq.com. To prevent taxpayers from claiming what the Internal Revenue Service (the IRS) believes to be an unintended double tax benefit under the Paycheck Protection Program (PPP), the IRS issued Notice 2020-32, 2020-21 I.R.B. 1 (the "Notice") to deny deductions for the payment of expenses resulting in the complete or partial forgiveness of a covered PPP loan.
IRS Announces that Expenses Giving Rise to the Forgiveness of a Paycheck Protection Program Loan | 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.
Html.Raw(CLAIMING REFUNDS FOR CORPORATE NET OPERATING LOSS CARRYBACKS UNDER THE CARES ACT - Coronavirus (COVID-19) - United States)
To print this article, all you need is to be registered or login on Mondaq.com. Under the Coronavirus Aid, Relief and Economic Security Act (the CARES Act), corporations, partnerships and certain other taxpayers are permitted to carryback net operating losses (NOLs)1 up to five years from taxable years 2018, 2019 and 2020.
IRS Permits First Spin-Off Of R&D Intensive Business With No Pre Spin-Off Income
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IRS Permits First Spin-off of R&D Intensive Business With No Pre Spin-off Income | 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.
Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities | 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.
Proposed Section 382 Regulations Would Eliminate Section 338 Approach of Notice 2003-65 | JD Supra
On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously taxpayer-favorable positions regarding the treatment of built-in gains and built-in losses for purposes of section 382(h).
Drowning in a Sea of Numbers? Mastercard and Strands Helps Small Business Owners Navigate Cash Flow Management
You may have heard of the expression “drinking from the firehose.” You’ve probably experienced it – an information overload so extreme that the incoming becomes unintelligible; the press of incoming responsibilities overwhelming an already mile-long to-do list, making even the simplest task seem impossible to complete.
Attacking the Achilles Heel of Small Businesses: Cash Flow Management
By Jay Singer For many small business owners, keeping the lights on—literally—is a juggling act. Cash inflow is the lifeblood of every business, fueling all aspects of operations from employee salaries to electricity. So it’s no surprise that poor cash flow management is one of the top reasons small businesses fail.
Tax Takes Video: Steering Clear of the BEAT
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Section 163(j) Interest Expense Limitation | JD Supra
The newly enacted version of section 163(j) limits deductions for business interest expense. In general, it limits a taxpayer’s interest expense deductions for a taxable year to the sum of 30 percent of adjusted taxable income (ATI) and its business interest income. Certain taxpayers involved in the sale of motor vehicles may also be able to increase their section 163(j) limitation by any floor plan financing interest expense.
How Small and Medium Sized Businesses Can Go Big in Trade
Small and Medium enterprises (SMEs) are the backbone of the world’s economy, yet they remain largely ignored by the industry and governments when it comes to developing new technology solutions or policies for global trade. SMEs account for 90 percent of the world’s businesses and are expected to contribute 600 million jobs by 2030. Despite their contribution to the global economy, these businesses have trouble entering and competing cross-border trade.
The Impact of Tax Reform on Private Equity and M&A Transactions
The 2017 tax reform act, entitled “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018” (the Act), is now law, leaving private equity and M&A professionals to digest these significant changes and reconcile the new provisions with how they do business. The following is a summary of important features of the Act that will affect private equity and M&A transactions going forward.
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