May 28, 2020 - The U.S. Treasury Department has issued regulations for debt-equity recharacterization under section 385 of the Internal Revenue Code (the Final Regulations) that finalize without substantive change proposed regulations promulgated in October 2016 (the 2016 Proposed Regulations). Section 385...
The U.S.’s Illusionary Turn to Territoriality
In this article from Tax Notes International, Davies partner Nathan Boidman contends that the sponsors of the Tax Cuts and Jobs Act not only failed to deliver on their promise of a territorial system for controlled foreign corporations, but also expanded the pre-existing quasi-worldwide system.
May 27, 2020 - As part of the federal government’s response to the COVID-19 pandemic, the Department of Finance recently published a draft legislative proposal, the Time Limits and Other Periods Act (COVID-19) (Proposal), that, if implemented, would provide for an automatic six-month suspension of...