Kathleen R Semanski
Kathleen Semanski is an associate in the Tax Department. She counsels corporate, private equity, investment fund and REIT clients in connection with domestic and cross-border financings, debt restructurings, taxable and tax-free mergers and acquisitions (inbound and outbound), securities offerings, fund formations, joint ventures and other transactions. Katie also advises on structuring for inbound and outbound investments, tax treaties, anti-deferral regimes, and issues related to tax withholding and information reporting. Katie is a regular contributor to the Proskauer Tax Talks blog where she has written about developments in the taxation of cryptocurrency transactions, among other topics.
Katie earned her L.L.M. in taxation from NYU School of Law and her J.D. from UCLA School of Law, where she completed a specialization in business law & taxation and was a recipient of the Bruce I. Hochman Award for Excellence in the Study of Tax Law. Katie currently serves on the Pro Bono Initiatives Committee at Proskauer and has worked on a number of immigration, voting rights, and criminal justice-related projects.
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This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance issued by the Internal Revenue Service with respect to the taxation of digital assets. Summary of the Guidance: The Responsible Financial Innovation Act (the “RFIA”) introduced in Congress by Senators Cynthia Lummis (R-WY) … Continue Reading
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) (H.R. 748). This blog post summarizes the tax provisions of the CARES Act, and has been updated to reflect subsequent guidance from the Internal Revenue Service (“IRS”) on these provisions, and the Paycheck Protection Program Flexibility … Continue Reading
Today, March 23, 2020, for the second time the Senate defeated a procedural motion on a third stimulus bill, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) (H.R. 748). The vote was 49 in favor and 46 opposed (yesterday, the vote was 47 to 47). Sixty votes were required to advance the legislation. … Continue Reading
The first official guidance on the taxation of cryptocurrency transactions in more than five years has been issued. The guidance includes both a Revenue Ruling (Rev. Rul. 2019-24, 2019-44 I.R.B. 1) and answers to Frequently Asked Questions on Virtual Currency Transactions (the “FAQs,” together with Revenue Ruling 2019-24, the “Guidance”) was issued on October 9, … Continue Reading
Introduction On October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”)[1] that are likely to allow many controlled foreign corporations (“CFCs”)[2] of U.S. multi-national borrowers to guarantee the debt of their parents and to allow the U.S. parent to pledge more than 66 … Continue Reading
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
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee on Taxation estimated budget effects (commonly referred to as the “score”). Next week the House and Senate are each … Continue Reading
In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation (the “House bill”). Members of the House and Senate will next convene in conference to … Continue Reading
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of cryptocurrency transactions. The following is a very high-level discussion of the consequences generally applicable to U.S. individual holders of … Continue Reading
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late last night the Senate Finance Committee approved its own conceptual version of the Tax Cuts and … Continue Reading
On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS), originally published on November 24, 2016 (the “Multilateral Instrument,” or “MLI”). The Multilateral Instrument is the product of ongoing efforts by the Organisation … Continue Reading
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on November 24, 2016. The Convention is the latest in an ongoing series of releases related to the OECD/G20 Project addressing Base Erosion and Profit Shifting … Continue Reading
Recent Legislative Proposals and IRS Guidance on the Taxation of Digital Assets
Coronavirus: President Trump Signs the CARES Act; Summary of the Tax Provisions of the Act
Coronavirus: CARES Act Vote Fails in Senate; Summary of the Tax Provisions of the Bill
By Muhyung (Aaron) Lee, David S. Miller, Kathleen R Semanski and Sean Webb on Posted in Coronavirus, In the news, Tax Policy
IRS answers some, but not all, questions in long-awaited cryptocurrency guidance
By Jeremy Naylor, Kathleen R Semanski and Michael Fernhoff on Posted in Cryptocurrency, IRS
Impact of Proposed Regulations under Section 956 on Lending Arrangements Involving U.S. Corporate Borrowers
By Annie Kim, David S. Miller, Kathleen R Semanski, Martin T. Hamilton and Xiaoyang Ma on Posted in Corporate Taxation, International Taxation, IRS
Impact of Recent Tax Legislation on M&A Transactions
By Martine Seiden Agatston, Malcolm Hochenberg, Martin T. Hamilton, Kathleen R Semanski, Amy Zelcer, Alan Parnes, Amanda H. Nussbaum, Abraham Gutwein and Richard M. Corn on Posted in Corporate Taxation, Cost Recovery, In the news, International Taxation, Mergers & Acquisitions, Partnership Taxation, Tax Reform
House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference Agreement and Differences from House and Senate Versions
U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and Outstanding Differences to be Resolved in Conference
By Richard M. Corn, David S. Miller, Kathleen R Semanski, Martin T. Hamilton and Steven Einhorn on Posted in Corporate Taxation, Executive Compensation, International Taxation, Inversions, Partnership Taxation, Performance-Based Compensation, Real Estate, Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation
By Kathleen R Semanski on Posted in Blockchain, Cryptocurrency, IRS
House of Representatives Passes the Tax Cuts and Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison of the Bill Passed by the House and the Modified Senate Bill
By Steven Einhorn, Martin T. Hamilton, Kathleen R Semanski, David S. Miller and Richard M. Corn on Posted in Base Erosion and Profit Shifting, Employee Benefits, Executive Compensation, financial products, International Taxation, Partnership Taxation, Performance-Based Compensation, Real Estate, Tax Cuts and Jobs Act, Tax Reform, U.S. Inbound Real Estate Investment, U.S. Legislation
