Tax Relief May be Ahead for Market Participants Transitioning Away from LIBOR

Tax relief may be coming for issuers and holders of debt instruments and parties to derivatives and other financial contracts governed by LIBOR (the London Interbank Offered Rate). The IRS published new proposed regulations on October 9 to address tax concerns as parties have begun to modify financial instruments’ reference rates in anticipation of a

Dana Trier: 2019 Fogel Lecture

In the 2019 Fogel Lecture, Dana Trier, former Deputy Assistant Secretary for Tax Policy at the U.S. Department of the Treasury, urged the audience to give the “grand experiment” of §199A of the 2017 Tax Cuts and Jobs Act (which provides a deduction for qualified business income from pass-through entities) a chance, despite potentially troubling ambiguities.

NJ Appellate Court Affirms Decision Denying Interest Expense Addback Exception

The New Jersey Superior Court, Appellate Division, has affirmed the Tax Court’s decision in Kraft Foods Global Inc., in which a taxpayer’s deduction for related-party interest expense was disallowed for corporation business tax purposes (decision available here). Background The only issue before the court was whether the Division of Taxation (the “Division”) properly added back