Tax Talks

The Proskauer Tax Blog

Alan Parnes

Alan Parnes

Partner

Alan P. Parnes is a partner in the Tax Department and a leader of the transactional tax team in the New York office. He has been practicing law since 1977 and has been at Proskauer since 1980.

Alan’s tax practice is a broad-based commercial tax practice. In the international tax area, he has counseled U.S. clients establishing operations and conducting business overseas through wholly owned subsidiaries and joint ventures with both domestic and foreign partners, as well as clients exporting products to foreign markets and licensing intangible property to foreign licensees. In this aspect of his practice, Alan has focused on issues involving U.S. tax deferral, the minimization of foreign income, withholding and other taxes, intercompany pricing and the maximization of available foreign tax credits. He has also counseled foreign clients on the many tax issues involved in conducting business in the U.S. Alan also is a member of Proskauer's nationally recognized Lodging & Gaming Group and has consulted on tax matters in almost every aspect of the hospitality industry.

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The Second Set of Proposed Opportunity Zone Regulations

Introduction On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section 1400Z-2 of the Internal Revenue Code (the “Code”) regarding the qualified opportunity zone program, which was enacted as part of the law commonly … Continue Reading

Players, Staff and Draft Picks May be Traded Tax-Free Under New Safe Harbor

On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for players, coaches and managers) and draft picks as having a zero value for determining gain or loss recognized for federal income tax purposes … Continue Reading

Proposed FDII Regulations under Section 250

I.                   Introduction. On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible income” (“FDII”) under section 250 of the Internal Revenue Code.[1] Section 250 was enacted in 2017 as part of the tax reform act.[2] … Continue Reading

“Passthrough Deduction” Regulations Finalized

On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or business income under section 199A of the Internal Revenue Code.[1] The Final Regulations modify proposed regulations (the “Proposed Regulations”) that were released in August … Continue Reading

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.  Some of these rules are very complex, particularly in cross-border transactions, and this post describes them in general terms without all of their fine details.  The discussion of foreign … Continue Reading

Tax Reform’s Effect on the Sports Industry

On Friday, December 22, 2017, President Trump signed into law H.R. 1, the $1.5 trillion tax reform law known as the Tax Cuts and Jobs Act (the “Tax Reform Act”). This alert describes provisions of the Tax Reform Act that we expect will have the most significant impact and immediate effect on the sports industry. Unless otherwise noted, all proposals described below will be effective for taxable years beginning after December 31, 2017.… Continue Reading
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