On Monday, President Trump issued a flurry of executive orders on a wide variety of topics, many of which implement changes previewed during his presidential campaign. Three of the execu...
The IRS released proposed regulations pertaining to the Section 162(m) limits on the deduction for certain employee remuneration in excess of $1 million. The proposal provides for the ide...
The Trump administration is likely to prioritize tax reform, aligning with Trump’s previous stance on the 2017 Tax Cuts and Jobs Act (TCJA), and taxpayers should be attentive to these c...
On Tuesday, December 27, 2022, the IRS released a notice that describes proposed regulations that the IRS intends to issue addressing the application of the new corporate alternative mini...
Alternative tests are available to permit a “tack-on” offering to achieve tax fungibility even where the new notes are issued with more than de minimis OID.