Mani Kakkar
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On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”).[1] Section 163(j) limits the deductibility of net business interest expense to 30% of “adjusted taxable income” plus “floor plan financing … Continue Reading
On December 21st, 2015 the IRS proposed Country-by-Country (“CbC”) reporting rules requiring certain U.S. multinational companies to provide extensive information about business operations (including their revenue, number of employees, taxes paid or withheld, etc.) that may be shared with other taxing authorities under Information Exchange Agreements. The exchange of information is reciprocal; the IRS will … Continue Reading
The Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts (“REITs”) and investments by non-U.S. investors in U.S. real estate (commonly referred to as “FIRPTA”). For a detailed overview of these PATH Act changes, please … Continue Reading
Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256[1] to foreign currency options (and also, possibly, to foreign currency swaps or other, similar foreign currency derivatives). Section 1256 requires a taxpayer to treat certain types of derivative contracts held … Continue Reading
U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations
By Mani Kakkar, Richard M. Corn, Annie Kim, Amanda H. Nussbaum, David S. Miller, Martin T. Hamilton, Sejin Park and Sean Webb on Posted in Corporate tax, financial products, International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
IRS Proposes Country-by-Country Reporting Regulations
By Mani Kakkar, Martin T. Hamilton and Stuart Rosow on Posted in Base Erosion and Profit Shifting, International Taxation, IRS
Real Estate Investments by Qualified Foreign Pension Funds After the PATH Act
By Mani Kakkar, Amanda H. Nussbaum, Gary Silber, Leslie Loffman, Martin T. Hamilton, Rachel Hughes and Timothy Donovan on Posted in FIRPTA, Real Estate, REITs, U.S. Inbound Real Estate Investment
Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime
By Mani Kakkar, Richard M. Corn and Martin T. Hamilton on Posted in financial products, Notable Decisions
