December 12, 2018

Here's a summary of the potentially far-reaching tax consequences of the anticipated phase-out of LIBOR.

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The IRS and Treasury have issued proposed regulations on the new interest expense deduction limitations.  

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The Second Circuit recently held that the extension of a derivative was a deemed taxable exchange.

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The market is seeing increasing traffic on the taxable spin-off road to REIT conversions.

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The White House Office of Management and Budget has begun reviewing proposed rules relating to Section 1446(f), which potentially requires a purchaser of partnership equity to withhold on a foreign seller.  The office has up to 45 days to review the proposed rules before they are published.

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