Sejin Park
Sejin Park is an associate in the Tax Department. Sejin’s practice focuses on advising clients on tax matters in domestic and cross-border transactions related to capital markets, finance, mergers & acquisitions and bankruptcy.
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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
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
The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program. The program is designed to encourage investment in distressed communities designated as “qualified opportunity zones” by providing tax incentives to invest in “qualified opportunity funds” (“opportunity funds”) that, in turn, invest directly or indirectly … Continue Reading
The Second Set of Proposed Opportunity Zone Regulations
By David S. Miller, Jean Bertrand, Sejin Park, Sean Webb, Amanda H. Nussbaum, Ira G. Bogner, Richard M. Corn, Martin T. Hamilton, Malcolm Hochenberg, Scott S. Jones, Mary B. Kuusisto, Arnold P. May, Jeremy Naylor, Alan Parnes, Jamiel E. Poindexter and Stuart Rosow on Posted in IRS, Opportunity Zones, Tax Cuts and Jobs Act, Tax Reform
U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations
By Martin T. Hamilton, Annie Kim, David S. Miller, Amanda H. Nussbaum, Richard M. Corn, Sejin Park, Mani Kakkar 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