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Articles by John Narducci
Flips from the UK to the US – Key UK and US Tax Considerations | JD Supra
The insertion of a US holding company by way of a share-for-share exchange, whereby the shares in an existing UK company (“UKCo”) are transferred to a new US company (“USCo”) in exchange for shares issued by USCo, is commonly referred to as a ‘flip’ transaction. A flip transaction is typically contemplated to facilitate raising capital from US-based venture funds. This note highlights some of the key UK and US tax considerations that can be relevant in the context of such a flip transaction.
IRS Issues Direct Pay and Transferability Proposed Regulations | JD Supra
On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable energy: (1) “direct pay,” allowing certain tax-exempt, taxable and government entities to elect to receive cash payments from the federal government in lieu of energy tax credits and (2) “transferability,” allowing the transfer of energy tax credits to unrelated parties...
IRS issues direct pay and transferability proposed regulations
On June 14, 2023, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) under two novel provisions of the Inflation Reduction Act of 2022 (the “IRA”) designed to promote capital investment in renewable energy: (1) “direct pay,” allowing certain tax-exempt, taxable and government entities to elect to receive cash payments from the federal government in lieu of energy tax credits and (2) “transferability,” allowing the transfer of energy tax credits to unrelated parties...
Good News for PPP Loan Recipients: Deferrals for Employer Portion of Social Security Tax Now Available | JD Supra
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” (Public Law 116-136)) allows employers and self-employed individuals to defer payment of the employer share of the Social Security tax from March 27, 2020 (the date of its enactment) through December 31, 2020, that they otherwise would be responsible for paying to the federal government with respect to their employees. Employers generally are responsible for paying a 6.2-percent Social Security tax on employee wages.
EU Introduces New Reporting Requirements For Certain Cross-Border Transactions | JD Supra
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Private Equity Fund Taxation Post-Tax Reform: What Really Changed?
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Private Equity Fund Taxation Post-Tax Reform: What Really Changed?
Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will impact private equity funds, for good or ill.
International Provisions in U.S. Tax Reform - A Closer Look
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The Impact on Financing Transactions if the House’s “Tax Cuts and Jobs Act” Passes
On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act (“H.R. 1”), and later proposed amendments to the bill on November 3, November 6, and November 9, 2017. H.R. 1, if passed, would make certain fundamental changes to the taxation of financing transactions.
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