Identifying obscure but potentially costly tax issues is a skill. Solving them in the context of our client’s goals is an art, and one that Paul, Weiss practices at the highest level. Working closely with the Corporate and Bankruptcy Departments, our tax lawyers help clients solve problems, avoid pitfalls and uncover hidden value in all types of transactions.
Jeffrey Samuels to Participate in Tax Executives Institute’s M&A Seminar
Tax partner Jeffrey Samuels will speak on a panel at the Tax Executives Institute’s 2019 Mergers and Acquisitions seminar. Jeffrey’s panel will address “Post-Merger Integration: Putting the Pieces Together After Tax Reform.” The event will take place from November 18 to 19 in Las Vegas.
Events & Publications
IRS Issues Proposed Regulations Providing Guidance on Taxation of Carried Interest from Investment Partnerships under Section 1061
- Aug 04, 2020
- Publications
IRS Issues Proposed Regulations Providing Guidance on Taxation of Carried Interest from Investment Partnerships under Section 1061
The IRS and the Treasury Department recently released proposed regulations on the scope and applicability of Section 1061 of the Internal Revenue Code.
In Memoriam: David Sicular, July 17, 1957 – July 17, 2020
- Jul 19, 2020
- Firm News
In Memoriam: David Sicular, July 17, 1957 – July 17, 2020
The Paul, Weiss community mourns the loss of our beloved friend and partner, David Sicular, who passed away on July 17, 2020 – his 63rd birthday. There are no words to describe the pain that we are experiencing after his tragic and…
CARES Act Update: Internal Revenue Service Disallows Deduction of Certain Expenses Funded with PPP Loan Proceeds
- May 07, 2020
- Publications
CARES Act Update: Internal Revenue Service Disallows Deduction of Certain Expenses Funded with PPP Loan Proceeds
The IRS recently issued a notice specifying that taxpayers that receive a loan under the CARES Act’s Paycheck Protection Program may not deduct business expenses funded with PPP loan proceeds to the extent the PPP loan is forgiven.
Internal Revenue Code Section 83(b) Deadline Extended to July 15, 2020 as a Result of COVID-19
- Apr 20, 2020
- Publications
Internal Revenue Code Section 83(b) Deadline Extended to July 15, 2020 as a Result of COVID-19
As a result of the COVID-19 pandemic, the 30-day period for making an Internal Revenue Code Section 83(b) election with respect to grants of restricted property has been extended to July 15, 2020.
CARES Act: Federal Income Tax Relief for Individuals and Businesses in Response to the Coronavirus Pandemic
- Mar 27, 2020
- Publications
CARES Act: Federal Income Tax Relief for Individuals and Businesses in Response to the Coronavirus Pandemic
The CARES Act makes a number of significant changes to the federal income taxation of both individual taxpayers and businesses that are generally intended to provide near-term liquidity and economic relief.
Paul, Weiss Adds Leading Tax Partner
- Mar 23, 2020
- Firm News
Paul, Weiss Adds Leading Tax Partner
Robert Holo has joined the firm as a partner in the Tax Department, resident in the New York office.
Internal Revenue Service Postpones April 15 Federal Income Tax Payment and Tax Return Filing Deadlines
- Mar 22, 2020
- Publications
Internal Revenue Service Postpones April 15 Federal Income Tax Payment and Tax Return Filing Deadlines
On March 20, the Internal Revenue Service issued Notice 2020 18 postponing the April 15 federal income tax payment and tax return deadline to July 15, 2020. The Notice supersedes the relief previously issued in Notice 2020-17…
Internal Revenue Service Postpones Certain April 15 Federal Income Tax Payment Deadlines
- Mar 18, 2020
- Publications
Internal Revenue Service Postpones Certain April 15 Federal Income Tax Payment Deadlines
On March 18, the IRS announced that individual taxpayers would be allowed to defer up to $1 million and corporations would be allowed to defer $10 million of federal income tax payments (including federal estimated income tax…
Jeffrey Samuels to Participate in Tax Executives Institute’s M&A Seminar
- Nov 18, 2019
- Events
Jeffrey Samuels to Participate in Tax Executives Institute’s M&A Seminar
Tax partner Jeffrey Samuels will speak on a panel at the Tax Executives Institute’s 2019 Mergers and Acquisitions seminar.
IRS Revenue Procedure and Proposed Regulations Provide Modest Relief on Controlled Foreign Corporation Issues
- Oct 17, 2019
- Publications
IRS Revenue Procedure and Proposed Regulations Provide Modest Relief on Controlled Foreign Corporation Issues
The IRS and the Department of the Treasury recently issued Revenue Procedure 2019-40 and proposed regulations that modestly narrow the implications of the 2017 repeal of Section 958(b)(4) of the U.S. Internal Revenue Code.
Federal Agencies Issue Joint Statement on AML/CFT Obligations, and IRS Updates Guidance, for Digital Assets
- Oct 15, 2019
- Publications
Federal Agencies Issue Joint Statement on AML/CFT Obligations, and IRS Updates Guidance, for Digital Assets
The CFTC, the SEC and FinCen recently issued a joint statement reminding those engaged in activities involving digital assets of their anti-money laundering and counter-terrorist funding obligations under the Bank Secrecy Act
IRS Proposes to Eliminate Taxpayer Favorable Safe Harbor for Corporations after Ownership Change
- Sep 12, 2019
- Publications
IRS Proposes to Eliminate Taxpayer Favorable Safe Harbor for Corporations after Ownership Change
On Monday, September 9, 2019, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) released proposed regulations (the “Proposed Regulations”) under Section 382 of the U.S. Internal Revenue Code of 1986, …
Paul, Weiss Partners to Lead PLI Briefing on Real Asset Funds
- Sep 12, 2019
- Events
Paul, Weiss Partners to Lead PLI Briefing on Real Asset Funds
Corporate partner Udi Grofman, real estate partner Harris Freidus and tax partner David Mayo will lead a one-hour Practising Law Institute briefing, “Real / Hard Asset Funds: Real Estate and Infrastructure.”
Final and Proposed Regulations on Certain Income Inclusions Under the CFC Rules Related to Domestic Partnerships
- Jun 20, 2019
- Publications
Final and Proposed Regulations on Certain Income Inclusions Under the CFC Rules Related to Domestic Partnerships
The IRS and Treasury recently released proposed and final regulations that, among other things, change the way income inclusions work under the Subpart F and GILRI rules with respect to foreign corporations that are CFCs owned by…
Final Regulations on Section 956 and “Deemed Dividends” from Controlled Foreign Corporations
- May 29, 2019
- Publications
Final Regulations on Section 956 and “Deemed Dividends” from Controlled Foreign Corporations
On May 22, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released final regulations (the “Final Regulations”) under Section 956 of the U.S. Internal Revenue Code of 1986, as amended…
Paul, Weiss Hosts Annual Private Equity General Counsel CLE
- May 15, 2019
- Events
Paul, Weiss Hosts Annual Private Equity General Counsel CLE
Paul, Weiss hosted its Annual Private Equity General Counsel CLE Program.
New Proposed Regulations on Section 956 and “Deemed Dividends” from Controlled Foreign Corporations
- Nov 01, 2018
- Publications
New Proposed Regulations on Section 956 and “Deemed Dividends” from Controlled Foreign Corporations
On October 31, 2018, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) released proposed regulations (the “Proposed Regulations”) under Section 956 of the U.S. Internal Revenue Code of 1986, as…
New IRS and Treasury Guidance on Qualified Opportunity Zone Program
- Oct 23, 2018
- Publications
New IRS and Treasury Guidance on Qualified Opportunity Zone Program
As part of the U.S. federal tax legislation enacted into law last year, Congress added provisions that provide tax benefits to encourage investments in designated low-income communities known as qualified opportunity zones (“QOZs”).
Treasury Department Releases Regulations Concerning Section 199A
- Aug 24, 2018
- Publications
Treasury Department Releases Regulations Concerning Section 199A
Recently-enacted Section 199A allows individuals, trusts and estates to deduct up to 20% of “qualified business income” from certain businesses operated in pass-through form (the “Section 199A Deduction”), and is intended to provide…
First IRS Guidance on Expanded Section 162(m)’s $1 Million Deduction Limitation: No Grandfathering Relief For Negative Discretion Amounts; Many Questions Remain
- Aug 24, 2018
- Publications
First IRS Guidance on Expanded Section 162(m)’s $1 Million Deduction Limitation: No Grandfathering Relief For Negative Discretion Amounts; Many Questions Remain
The Internal Revenue Service recently released Notice 2018-68, which provides initial guidance about the 2017 amendments to Internal Revenue Code Section 162(m).
David Mayo Participates in Program on Effects of Tax Act on Law Firms
- Feb 28, 2018
- Events
David Mayo Participates in Program on Effects of Tax Act on Law Firms
Tax partner David Mayo spoke on a panel at Sandpiper Partners LLC’s program, “Challenges & Changes for Law Firms and Their Partners Under the Tax Act of 2017.”
The Effect of the Tax Cuts and Jobs Act on Employer Settlements of Sexual Harassment Claims
- Jan 22, 2018
- Publications
The Effect of the Tax Cuts and Jobs Act on Employer Settlements of Sexual Harassment Claims
A little-publicized provision of the tax law enacted last month bars companies from deducting one type of settlement as a business expense: settlement payments and associated attorneys’ fees related to sexual harassment or abuse where …
Update on the Enactment of the Tax Cuts and Jobs Act
- Jan 03, 2018
- Publications
Update on the Enactment of the Tax Cuts and Jobs Act
On December 22, President Trump signed Public Law No. 115-97, formerly known as the “Tax Cuts and Jobs Act” (the “Act”), into law. In this memorandum, we summarize key provisions of the Act, including those concerning individuals,…
Paul, Weiss Announces Election of Five New Partners
- Dec 01, 2017
- Firm News
Paul, Weiss Announces Election of Five New Partners
Paul, Weiss announced that five new partners have been elected to the partnership, effective January 1, 2018: Yahonnes Cleary, Brian S. Grieve, Kyle J. Kimpler, Lindsay B. Parks and Ramy J. Wahbeh.
Update on the Tax Cuts and Jobs Act
- Nov 14, 2017
- Publications
Update on the Tax Cuts and Jobs Act
The Senate Finance Committee released its draft of the Tax Cuts and Jobs Act on November 9. The Senate’s initial tax reform proposal differs substantially from the House version. We compare the two proposals, and also describe…
Introduction to the Tax Cuts and Jobs Act
- Nov 07, 2017
- Publications
Introduction to the Tax Cuts and Jobs Act
On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) released a comprehensive tax reform bill titled the “Tax Cuts and Jobs Act,” on November 3, 2017 Chairman Brady proposed an Amendment in the Nature of a…
Treasury Reveals Plans Regarding Certain 2016 Tax Rules, Including Disguised Sale and Debt/Equity Regulations
- Oct 10, 2017
- Publications
Treasury Reveals Plans Regarding Certain 2016 Tax Rules, Including Disguised Sale and Debt/Equity Regulations
The United States Department of the Treasury submitted its highly anticipated final report to President Trump announcing its plans to pare back eight tax regulations that it had previously identified in June of 2017 under Executive…
Larry Witdorchic to Participate in PLI Conference on Tax Strategies in M&A
- Nov 15, 2017
- Events
Larry Witdorchic to Participate in PLI Conference on Tax Strategies in M&A
Employee benefits partner Larry Witdorchic will speak on a panel at the Practising Law Institute’s upcoming conference on 2017 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings,…
Delaware Supreme Court Affirms Decision Permitting Merger Termination Based on Failure to Satisfy Tax Opinion Covenant
- Mar 27, 2017
- Publications
Delaware Supreme Court Affirms Decision Permitting Merger Termination Based on Failure to Satisfy Tax Opinion Covenant
In a 4-1 split decision in The Williams Cos., Inc. v. Energy Transfer Equity, L.P., et al., the Delaware Supreme Court affirmed the Court of Chancery’s decision permitting termination of a merger agreement by the acquirer based on the …
Transactional Real Estate: Investing in U.S. Real Estate Using Domestically-Controlled REITS
- Feb 15, 2017
- Publications
Transactional Real Estate: Investing in U.S. Real Estate Using Domestically-Controlled REITS
Real estate partner Mitch Berg and tax partner Scott Sontag published a quarterly real estate column in the February 15 issue of the New York Law Journal.
Client Alert: Proposed Treasury Regulations Would Alter Valuation of Closely-Held Interests and Affect Estate Planning
- Nov 08, 2016
- Publications
Client Alert: Proposed Treasury Regulations Would Alter Valuation of Closely-Held Interests and Affect Estate Planning
The IRS issued proposed regulations in August taking aim at valuation discounts with respect to closely-held interests for gift, estate and generation-skipping transfer tax purposes. If adopted, the proposed regulations…
Client Alert: Treasury Issues Final Debt/Equity Regulations, Tempers Controversial Approach Taken in Proposed Regulations
- Oct 28, 2016
- Publications
Client Alert: Treasury Issues Final Debt/Equity Regulations, Tempers Controversial Approach Taken in Proposed Regulations
On October 13, 2016, the U.S. Department of Treasury released the highly-anticipated final and temporary regulations under Section 385 of the Internal Revenue Code.
Client Alert: New Regulations Eliminate Leveraged Partnership Transactions, Modify Proposed Rules for Allocation of Partnership Liabilities
- Oct 19, 2016
- Publications
Client Alert: New Regulations Eliminate Leveraged Partnership Transactions, Modify Proposed Rules for Allocation of Partnership Liabilities
On October 5, 2016, the U.S. Department of Treasury and the Internal Revenue Service (together referred to as the "Service") finalized previously proposed regulations regarding the allocation of partnership liabilities and…
Client Alert: Treasury Proposes Changes to Tax-Free “Spin-Off” Rules
- Jul 21, 2016
- Publications
Client Alert: Treasury Proposes Changes to Tax-Free “Spin-Off” Rules
On July 14, 2016, the U.S. Department of Treasury issued proposed regulations and on July 15, 2016 the IRS issued Revenue Procedure 2016-40, both regarding the requirements for a tax-free spin-off pursuant to Section 355 of the…
Client Alert: Treasury Issues Inversion Regulations, Proposes Sweeping Changes to Debt/Equity Classification
- Apr 11, 2016
- Publications
Client Alert: Treasury Issues Inversion Regulations, Proposes Sweeping Changes to Debt/Equity Classification
On April 4, 2016, as the most recent step in its ongoing battle against inversion transactions, the U.S. Department of Treasury issued both new temporary and proposed regulations addressing certain inversion and post-inversion…
Jeff Samuels Quoted on New Inversion Rules in The Wall Street Journal
- Apr 07, 2016
- Publications
Jeff Samuels Quoted on New Inversion Rules in The Wall Street Journal
Tax partner Jeffrey Samuels was quoted in an April 7 article in The Wall Street Journal, titled "New Inversion Rules Draw Concerns Outside U.S."
Client Alert: Fiscal Year 2017 Budget Update
- Feb 10, 2016
- Publications
Client Alert: Fiscal Year 2017 Budget Update
On Tuesday, February 9, 2016, the White House released President Obama's Budget for Fiscal Year 2017.
David Sicular to Deliver Annual Report at NYSBA Tax Section’s Annual Conference
- Jan 25, 2016
- Events
David Sicular to Deliver Annual Report at NYSBA Tax Section’s Annual Conference
Tax partner David Sicular, chair of the Tax Section of the New York State Bar Association (NYSBA), presided over and delivered the annual report presentation at the NYSBA Tax Section's annual meeting. The event took place on…
Update: PATH Act Enacts Notable Changes to REIT and FIRPTA Provisions
- Jan 05, 2016
- Publications
Update: PATH Act Enacts Notable Changes to REIT and FIRPTA Provisions
On Friday, December 18, 2015, President Barack Obama signed the "Protecting Americans from Tax Hikes Act of 2015" ("PATH Act").
Awards & Recognition
KPS Capital Wins Buyouts “Deal of the Year” Award
- Mar 21, 2017
- Awards
KPS Capital Wins Buyouts “Deal of the Year” Award
Paul, Weiss client KPS Capital Partners LP has earned a Buyouts “Deal of the Year” award for KPS’s $1 billion-plus sale of its portfolio company Anchor Glass Container Corporation to BA Glass B.V. and funds advised by CVC Capital…