Recent insights
Executive Summary: Final Treasury Regulations Clarify Business Interest Deduction Limitation
On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the …
Final Treasury Regulations Clarify Business Interest Deduction Limitation
Background On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on …
Restructuring and turnaround: tax implications of financial restructurings (Germany)
Long-Awaited Treasury Regulations Address the Application of Section 1061 to Carried Interests
On July 31, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REGS-107213-18) …
Germany: DAC6 – The impact of the new EU Disclosure Rules on Lending Transactions
“Real Estate Loan Purchases: Questions to Ask Before Finalizing a Deal”
In an environment where real estate values are fluctuating and cash flows are difficult to predict, it is more important than ever to apply a …
Tax Treaty Interpretation: The Limits of Fiction
New Treasury Regulations Address Disallowance of Deductions for Fines, Penalties and Other Amounts
On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that …
Treasury and the IRS Finalize Without Change October 2016 Proposed Regulations Treating Certain Related-Party Corporate Debt as Equity
On May 13, 2020, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) released regulations finalizing previously …
Rapid resolution of domicile disputes: be careful what you wish for
New Treasury Regulations Address Income Aggregation Rules for Tax-Exempt Organizations
On April 24, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-106864-18) …
COVID-19: Pressure Points: TAX RELIEF MEASURES (GERMANY)
Key contacts
William Arrenberg
Partner, London
Nicolás Martín
Partner, Madrid
Toby Eggleston
Partner, Melbourne
Jinny Chaimungkalanont
Managing Partner, Finance and Restructuring, Asia and Australia, Sydney
Nick Heggart
Partner, Perth
Hugh Paynter
Partner, Sydney
Ryan Leslie
Partner, Melbourne