Partners Alysse McLoughlin, Jay Singer, Todd Welty and Associate Michael Louis spoke at the 42nd Annual Tax Law Conference hosted in Washington, DC on March 9, 2018.
Jay Singer spoke at a session on “Section 355 Developments” which explored the future of Section 355 transactions and what the I.R.S. intends to accomplish in terms of guidance and rulings and discussed critical updates in this important area of the law that impacts numerous businesses.
Alysse McLoughlin was a panelist at a session on “State Impacts of Federal Tax Reform.” The panelists reviewed various important features of the new tax law reform—including the shift to the quasi-territorial system of taxation—and discussed how these features will, or will not, flow through to impact state tax liability and revenues in conforming states. The session also discussed how the federal system would be consistent or in conflict with state statutory objectives and US Constitutional requirements.
Todd Welty moderated and Michael Louis spoke on a panel on “Fees Relating to Debt Instruments and Other Securities” which discussed the 2017-18 Priority Guidance Plan includes a new project for guidance on the treatment of fees relating to debt instruments and other securities. The Tax Cuts and Jobs Act also places new limits on the deductibility of interest, similar to the interest barrier rules adopted in other countries. This panel also discussed issues related to the treatment of these fees, which may be more significant following the passage of the TCJA.