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 September 12, 2024, the U.S. Treasury Department and the Internal Revenue Service released proposed regulations addressing the application of the corporate alternative minimum tax that...
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...
On August 7, 2022, the United States Senate approved the Inflation Reduction Act of 2022 (H.R. 5376), an energy and healthcare bill that includes new tax provisions, including a new corpo...
On July 27, Sens. Schumer and Manchin announced an agreement on the Inflation Reduction Act of 2022. Key tax provisions include (1) imposing a 15% corporate AMT on the adjusted book inco...
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.
