January 17, 2019

Just over a year ago, we published a summary of 15 key provisions from the most significant revision to the U.S. tax code in over thirty years. Since then, the IRS and Treasury Department have been busy issuing much-needed guidance to interpret the new tax rules. Here is a snapshot of this guidance.

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On December 21, 2018, the IRS and Treasury issued final regulations on several topics under the centralized partnership audit regime.  

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Effective January 1, 2019, the UK’s rules regarding the taxation of corporate issuers and holders of hybrid capital debt instruments with equity-like features have changed.

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New commercial real estate collateralized loan obligation (CRE-CLO) issuances totaled approximately $13.9 billion in 2018, compared to approximately $7.7 billion in 2017. This past September, Cadwalader tax partners Jason Schwartz and Gary Silverstein authored an article for Bloomberg Tax on the tax considerations applicable to CRE-CLOs.

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Here is a summary of newly proposed regulations under Section 864(c)(8) of the tax code, which generally subjects foreigners to tax on a sale of equity in a partnership that is engaged in a U.S. trade or business.

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