Proposed Legislation Would Add Rural Opportunity Zones
January 26, 2024
Thomas Phelan (LAW ’11) authored an article discussing proposed legislation that would create rural opportunity zones as a tax incentive for economic development.
Internal Revenue Code
LeClairRyan Bankruptcy Highlights Pass-Through Tax Issue
Hannah Travaglini (LAW ’21) of Montgomery McCracken co-authored an article with Edward Schnitzer discussing the recent court decision in the LeClairRyan bankruptcy and, more broadly, the tax ramifications of different corporate entity structures during bankruptcy.
Pope & Talbot and a Slippery Slope: Distributions of Partnership Equity
Robert M. Kane, Jr. examines Pope & Talbot and argues that the IRS inappropriately relied on that case in two rulings addressing the calculation of section 311 gain on distributions of partnership equity.
When S Corporations Should Elect Entity Treatment for GILTI Purposes
This article analyzes Notice 2020-69 and the S corporations and shareholders that would benefit from electing entity treatment for the global intangible low-taxed income (GILTI) regime.
Proposed Regulations Broaden Limitation on Compensation Deductions for Public Companies
John Eagan (LAW ’79) and Stephen Bowers of White and Williams, LLP, discuss a few proposed regulatory changes under Internal Revenue Code Section 162(m), which limits the amount of compensation to certain individuals that a publicly traded company may deduct as a business expense.
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
Applying the Look-Through Rules in Determining ‘Investment Partnership’ Status Under Section 721(b)
Tax Time: Thomas D. Phelan (LAW ‘11) outlines how to apply the Look-Through Rules in Determining ‘Investment Partnership’ Status Under Section 721(b)