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November 15, 2018

Welcome to the first issue of BrassTax, a new monthly tax newsletter from Cadwalader.

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The U.S. Treasury Department and the IRS have issued proposed regulations that dramatically reduce the risk that a guarantee by a controlled foreign corporation of its U.S. parent's loan would result in a taxable “deemed repatriation” of the CFC's earnings. 

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A new revenue procedure provides welcome insight into the government's views on a parent corporation's use of its subsidiary's debt to retire its own debt in connection with spinning off the subsidiary.

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There are rumblings that the IRS is actively auditing a number of investment professionals who have taken the position that they are not subject to self-employment tax on their share of net income from their limited partnership interests in management entities.

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The Chancellor of the Exchequer delivered the United Kingdom Budget for 2018 last month. Our Clients & Friends Alert outlines the Budget's key tax measures.

Proposed regulations provide details on capital gains tax reduction and deferral under the new Opportunity Zone program, which is designed to promote investments in economically distressed areas.  Our Clients & Friends Alert discusses the program and the proposed regulations.

Key Contacts

Linda Z. Swartz
T. +1 212 504 6062


Adam Blakemore
T. +44 (0) 20 7170 8697

Jon Brose
T. +1 212 504 6376

Andrew Carlon
T. +1 212 504 6378

Mark P. Howe
T. +1 202 862 2236

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