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Updated Procedures for Section 355 Private Letter Rulings: Rev. Proc. 2024-24 and Notice 2024-38

Joseph Pari — Mon, 13 May 2024 14:03:43 +0000

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. provides procedures for requesting private letter rulings from the IRS relating to certain matters pertaining to transactions intended to qualify under Section 355 and

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Here We Go – Excise Tax Proposed Regulations Largely “NSYNC” with Notice 2023-2

Joseph Pari — Tue, 23 Apr 2024 12:50:04 +0000

On April 9, 2024, the Treasury Department (the “Treasury”) and Internal Revenue Service (the “IRS”) issued 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

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IP Phone Home – IRS Issues New Proposed Rules on the Repatriation of Intangible Property

Devon Bodoh — Thu, 04 May 2023 14:59:56 +0000

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. Under these rules, when a U.S. transferor transfers intangible property to a foreign corporation in an otherwise tax-free exchange under Sections[1] 351 or 361, the U.S. transferor is treated as having sold the intangible property in exchange for annual royalty payments (an “annual inclusion”) over the useful life of the intangible property (or a lump sum payment in the case of a disposition of the intangible property following the initial outbound transfer). The U.S. transferor treats the annual inclusion and lump sum as ordinary income and royalties for purposes of determining source and the foreign tax credit limitation category. Final regulations under Section 367(d) were published on December 16, 2016 (the “367 Regulations”).

Inflation Reduction Act of 2022

Devon Bodoh — Wed, 24 Aug 2022 13:59:05 +0000

I. Introduction On August 7, 2022, the U.S. Senate passed legislation (H.R. 5376) that includes significant tax law changes (the Inflation Reduction Act or the Act). The Inflation Reduction Act is a reconciliation bill; all 50 Senate Democrats voted for the legislation and all 50 Senate Republicans voted against it, with Vice President Harris casting

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Final Debt/Equity Regulations

Devon Bodoh — Mon, 18 May 2020 17:38:22 +0000

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

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COVID-19 – Benefiting from Worthless Stock Losses

Devon Bodoh — Tue, 14 Apr 2020 01:44:00 +0000

As the economic effects arising from the worldwide spread of the novel Coronavirus (COVID-19) continue to develop, it is clear that forced closures, travel and trade restrictions, steep declines in demand, and other pressures will cause many businesses throughout the world to struggle. In these uncertain times, taxpayers may obtain a significant benefit by evaluating

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Guidance on Certain Net Operating Loss Elections Under the CARES Act

Devon Bodoh — Mon, 13 Apr 2020 07:58:00 +0000

On April 9, 2020, the Internal Revenue Service issued procedural guidance addressing the new 5-year net operating loss (NOL) carryback period enacted as part of the CARES Act. Specifically, Revenue Procedure 2020-24 provides detailed guidance on making an election to (i) waive the carryback period for an NOL arising in a taxable year beginning in

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Debt Buybacks— A Familiar Tool for New Circumstances

Joseph Pari — Fri, 03 Apr 2020 15:09:00 +0000

As a result of the recent COVID-19 health crisis and related market volatility, an increasing number of bank loans and high yield bonds are trading below par. These current market conditions present attractive de-levering opportunities for leveraged companies able to buy back their own debt, as well as sponsors seeking to purchase debt of their

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Impact of the International Provisions of the TCJA on Loss Corporations – GILTI

Devon Bodoh — Thu, 19 Mar 2020 13:35:46 +0000

With U.S. multinational corporations facing uncertain economic times due to the worldwide spread of the Coronavirus (COVID-19), there will be increased focus on the ability of these companies to use net operating losses (NOLs), both domestically and offshore. The interaction of the NOL rules and certain recently enacted international tax rules in the Tax Cuts

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