Weil Tax BLOG - Feed https://tax.weil.com/category/tax-reform/ Views and developments from the Tax Department at Weil Wed, 08 Apr 2026 16:47:38 +0000 hourly 1 Carried Interest: UK Tax Reform https://tax.weil.com/carried-interest/carried-interest-uk-tax-reform/ Mon, 04 Nov 2024 10:13:07 +0000 Aron Joy https://tax.weil.com/?p=2362 On 30 October 2024, the Chancellor delivered the Autumn Budget which included an announcement on the highly anticipated changes to the taxation of carried interest in the UK. The scope and scale of this potential overhaul have been a topic of intense debate since the Labour Party’s 2024 General Election manifesto pledged to “close the

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]]> On 30 October 2024, the Chancellor delivered the Autumn Budget which included an announcement on the highly anticipated changes to the taxation of carried interest in the UK. The scope and scale of this potential overhaul have been a topic of intense debate since the Labour Party’s 2024 General Election manifesto pledged to “close the

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]]> New IRS Proposed Regulations Address Dual Consolidated Loss Rules https://tax.weil.com/features/new-irs-proposed-regulations-address-dual-consolidated-loss-rules/ Thu, 08 Aug 2024 20:34:12 +0000 Devon Bodoh Madeline Joerg Sydnei Jones https://tax.weil.com/?p=2286 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. Specifically, the Proposed Regulations clarify the application of the existing dual consolidated loss (“DCL”) rules by providing guidance regarding: (i) the interplay of the DCL rules with the intercompany transaction regulations

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]]> Final Regulations: Guidance on Reporting and Payment of Excise Tax https://tax.weil.com/insights/final-regulations-guidance-on-reporting-and-payment-of-excise-tax/ Tue, 02 Jul 2024 15:52:31 +0000 Devon Bodoh Joseph Pari Grant Solomon https://tax.weil.com/?p=2266 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

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]]> 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

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]]> Clear as Mud – Chevron Irreverence and Tax Law https://tax.weil.com/insights/clear-as-mud-chevron-irreverence-and-tax-law/ Mon, 01 Jul 2024 13:28:01 +0000 Devon Bodoh Joseph Pari Grant Solomon https://tax.weil.com/?p=2264 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. Natural Resources Defense Council, 467 U.S. 837 (1984), and held that federal agency interpretations of law are not entitled to any deference (such as the deference provided to the Department

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]]> 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. Natural Resources Defense Council, 467 U.S. 837 (1984), and held that federal agency interpretations of law are not entitled to any deference (such as the deference provided to the Department

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]]> Supreme Court Abolishes Judicial Deference to Agency Interpretations of Law https://tax.weil.com/insights/supreme-court-abolishes-judicial-deference-to-agency-interpretations-of-law/ Fri, 28 Jun 2024 18:19:46 +0000 Mark Perry Josh Wesneski Max Bloom https://tax.weil.com/?p=2259 Today, 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. Natural Resources Defense Council, 467 U.S. 837 (1984), and held that agency interpretations of law are not entitled to any deference. By overruling what is known as “Chevron deference,”

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]]> Today, 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. Natural Resources Defense Council, 467 U.S. 837 (1984), and held that agency interpretations of law are not entitled to any deference. By overruling what is known as “Chevron deference,”

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]]> Proposed Treasury Regulations Update Tax Standards for Bad Debt Deductions by Regulated Financial Companies https://tax.weil.com/insights/proposed-treasury-regulations-update-tax-standards-for-bad-debt-deductions-by-regulated-financial-companies/ Fri, 05 Jan 2024 13:38:48 +0000 Devon Bodoh Joseph Pari Stuart J. Goldring Alfonso Dulcey Renan Rodriguez https://tax.weil.com/?p=2096 On December 28, 2023, the U.S. Treasury Department (“Treasury“) and the Internal Revenue Service (“IRS“) issued proposed regulations (REG-121010-17) updating the standards for when a debt instrument held by a regulated financial company or a member of a regulated financial company group will be conclusively presumed to be worthless for U.S. federal income tax purposes

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]]> On December 28, 2023, the U.S. Treasury Department (“Treasury“) and the Internal Revenue Service (“IRS“) issued proposed regulations (REG-121010-17) updating the standards for when a debt instrument held by a regulated financial company or a member of a regulated financial company group will be conclusively presumed to be worthless for U.S. federal income tax purposes

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]]> Chambers Expert Focus Weil Tax Insight Series: Tax Implications of New Rules Under the Advisers Act https://tax.weil.com/features/chambers-expert-focus-weil-tax-insight-series-tax-implications-of-new-rules-under-the-advisers-act/ Tue, 17 Oct 2023 13:20:16 +0000 Robert Frastai Andrew Morris https://tax.weil.com/?p=2021 In this edition of the Chambers Expert Focus Weil Tax Insight Series, Weil Tax partners Robert Frastai and Andrew Morris discuss the impact of the SEC’s recently adopted rules under the Investment Advisers Act of 1940 on certain tax structuring and compliance matters for private funds, including after-tax clawback obligations, blocker and withholding taxes that are allocated to

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]]> State of the Union: President Biden Calls for Increase to the Excise Tax https://tax.weil.com/insights/state-of-the-union-president-biden-calls-for-increase-to-the-excise-tax/ Wed, 08 Feb 2023 16:28:43 +0000 Devon Bodoh Joseph Pari Grant Solomon https://tax.weil.com/?p=1842 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

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]]> New IRS proposed regulation would reverse longstanding IRS ruling and upend commonly used real estate fund structures https://tax.weil.com/insights/new-irs-proposed-regulation-would-reverse-longstanding-irs-ruling-and-upend-commonly-used-real-estate-fund-structures/ Wed, 04 Jan 2023 15:23:32 +0000 Devon Bodoh Robert Frastai Hillel N. Jacobson Andrew Morris Lauren Gorsche https://tax.weil.com/?p=1816 Shortly before the new year, the Internal Revenue Service (“IRS”) dropped a holiday bombshell on the tax community when it issued a proposed regulation under the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). The proposed regulation would, if enacted in its current form, reverse a longstanding IRS ruling interpreting FIRPTA (the “2009

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]]> Shortly before the new year, the Internal Revenue Service (“IRS”) dropped a holiday bombshell on the tax community when it issued a proposed regulation under the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). The proposed regulation would, if enacted in its current form, reverse a longstanding IRS ruling interpreting FIRPTA (the “2009

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]]> Notice 2023-2: Proposed Guidance on the Stock Buyback Excise Tax https://tax.weil.com/insights/notice-2023-2-proposed-guidance-on-the-stock-buyback-excise-tax/ Thu, 29 Dec 2022 14:37:08 +0000 Devon Bodoh Joseph Pari Madeline Joerg Grant Solomon https://tax.weil.com/?p=1810 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[1]) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. For purposes of the Excise Tax,

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]]> 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[1]) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. For purposes of the Excise Tax,

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