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1
Proposed Regulations On Built-In Gains And Losses Under Section 382(h)
On September 10, 2019, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury (the "Treasury")
United States
25 Sep 2019
2
Proposed Regulations Provide Clarity For Qualified Foreign Pension Fund Exception
On June 7, 2019, the U.S. Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") released proposed Treasury regulations under Sections 897, 1445 and 1446.
United States
12 Jul 2019
3
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
4
Section 1446(f) Proposed Regulations: Key Guidance On Partnership Interest Transfers By Non-U.S. Persons
On May 13, 2019, the IRS and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests ...
United States
6 Jun 2019
5
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
6
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
7
Proposed Anti-Hybrid Regulations Under Sections 267A, 245A, And 1503(d)
On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
United States
30 Jan 2019
8
The Proposed BEAT Regulations
On December 13, 2018, the Internal Revenue Service and the Department of the Treasury released proposed regulations with respect to the "base erosion and anti-abuse tax" under section 59A of the Internal Revenue Code.
United States
7 Jan 2019
9
FATCA: Significant Relief In New Proposed Regulations
On December 13, 2018, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations
United States
21 Dec 2018
10
Newly Proposed US Tax Regulations Open Possibility Of Full Credit Support From Foreign Subsidiaries
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code.
United States
21 Nov 2018
11
Impact Of Proposed Regulations Under Section 956 On Lending Arrangements Involving U.S. Corporate Borrowers
Impact Of Proposed Regulations Under Section 956 On Lending Arrangements Involving U.S. Corporate Borrowers
United States
16 Nov 2018
12
Summary Of The Opportunity Zone Program
The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program.
United States
14 Nov 2018
13
IRS And Treasury Issue Proposed Opportunity Zone Regulations
The proposed regulations answer the most pressing questions with mostly taxpayer-friendly answers.
United States
23 Oct 2018
14
New Repatriation Tax Relief For RICs And Foreign Income Guidance For REITs
On September 6, the Internal Revenue Service ("IRS") released Revenue Procedure 2018-47 (the "RIC Rev Proc"), which provides that a repatriation deemed ...
United States
26 Sep 2018
15
Treasury And IRS Issue Proposed "Pass-Through Deduction" Regulations
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction"
United States
31 Aug 2018
16
Digital Economy: Supreme Court Overturns Physical Presence Requirement For State Sales Tax
In a landmark decision changing course on decades of precedent, the United States Supreme Court decided on June 21, 2018 South Dakota v. Wayfair, Inc., et al.
United States
3 Jul 2018
17
Tax Reform – I.R.S. Updates Withholding Tax Guidance On Sales Of Partnership Interests
On April 2, 2018, the Internal Revenue Service ("IRS") released Notice 2018-29[1] (the "Notice"), announcing the intention of the IRS and the Department of the Treasury to issue ...
United States
14 May 2018
18
Impact of Recent Tax Legislation On M&A Transactions
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the "Tax Act") that may affect M&A Transactions.
United States
12 Feb 2018
19
New Tax Law (H.R. 1): Key Highlights Related To Interest Bearing Debt
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
United States
15 Jan 2018
20
IRS Issues Taxpayer Advisory On Prepayment Of 2018 Property Taxes
The IRS announced yesterday, in IR 2017-210 (the "Advisory"), that state property taxes must be "assessed" in 2017 in order for such taxes to be prepaid in calendar year 2017 and therefore deductible in 2017.
United States
2 Jan 2018
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