Transactions involving the disposition of partnership property or partnership interests can trigger rules that limit business interest expense deductions. Section 163(j) of the Internal Revenue Code generally...
Interested in knowing what other partners are saying about how commercial lease agreements are evolving? Access exclusive market intelligence about private commercial lease agreements, as only told by...
The seller usually wants assurances that a buyer will be able to fund an acquisition at the closing, particularly if the closing is subject to a lengthy interim period between signing and closing. If a...
A company that receives a warning letter from the Food and Drug Administration (FDA) is on FDA's radar screen. In addition to responding appropriately to any actual or potential violations indicated...
We just added Arbitration Q&A content to Practical Guidance’s State Law Comparison Tool! Compare state laws on arbitration both pre-dispute and once a dispute arises across five key arbitration...
Not again! Treasury has issued proposed regulations concerning the foreign tax credit (again) that address the cost recovery, attribution for royalty payment withholding tax, and defining a reattribution asset for purposes of allocating and apportioning foreign taxes. 87 Fed. Reg. 71,271 (Nov. 22, 2022). Applicability dates vary, but in all events the regulationss provide taxpayers the option to apply the proposed regulations, once finalized, to all foreign taxes that were subject to the modified provisions of the regulations that were finalized on January 4, 2022 (see 87 Fed. Reg. 276 (Jan. 4, 2022)).
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