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.
