Section 112020 of the “One Big Beautiful Bill Act” (OBBBA), House version, would expand the reach of the IRC § 4960 excise tax on compensation in excess of $1 million (equal to 21%, the...
Read this practice note discussing factoring transactions, the parties involved, and the reasons for factoring. This practice note specifically discusses the distinguishing features of advance and discount...
Land banking transactions are an alternative financing structure where the land banker (typically an investment group) purchases the land shortly before or soon after the homebuilder acquires it. The parties...
Don’t miss out on what’s trending in the deal market. Find out how dealmakers are navigating valuation uncertainties with increasingly nuanced adjustment provisions, from working capital metrics...
Check out this video discussing best practices for responding to FDA Form 483 inspectional observations. Watch now » Related Content Life Sciences FDA Matters Representation and Warranty Clause...
* The views expressed in externally authored materials linked or published on this site do not necessarily reflect the views of LexisNexis Legal & Professional.
The Treasury and IRS issued proposed regulations under I.R.C. Section 951A providing guidance on passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs) held by domestic partnerships and S corporations. 87 Fed. Reg. 3,890 (Jan. 25, 2022). The proposed rules impact PFIC reporting and determine that domestic partnerships and S corporations should be treated as entities or aggregates of their partners and shareholders, respectively, for purposes of making qualified electing fund (QEF) or mark-to-market (MTM) elections, recognizing QEF inclusions or MTM amounts, or filing Forms 8621.
READ NOW »
Related Content
Practical Guidance Updates Featuring the latest updates from your Practical Guidance account.
Experience results today with practical guidance, legal research, and data-driven insights—all in one place.Experience Lexis+