Shearman And Sterling

Tax Bill, Supreme Court of the US, Washington DC

Aug 20, 2020

Final Regulations Under Code Section 163(j)

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FINAL REGULATIONS UNDER CODE SECTION 163(J)

Webcast

The Shearman & Sterling Tax team hosted a two-part discussion about the recently issued final regulations under Code Section 163(j) on August 19th and August 20th. Part 1, presented by partners Ryan Bray, Larry Crouch, Kristen Garry, Jay Singer, Nate Tasso provided an overview of Section 163(j) (including an analysis of what items are considered interest subject to limitation) and the key provisions in the final regulations relating to corporations and non-U.S. taxpayers. Part 2, presented by partners Todd Lowther and Mike Shulman, counsel Derek Kershaw and associate Julia Pashin provided a detailed analysis of the portions of the Section 163(j) final regulations relating to interest paid byPa partnerships and the applicability of the limitation to interest expense attributable to certain excepted businesses (including regulated utilities and electing real property businesses).


Authors and Contributors

Ryan Bray

Partner

Tax

+1 214 271 5680

+1 214 271 5680

+1 650 838 3726

+1 650 838 3726

Dallas

Larry Crouch

Partner

Tax

+1 650 838 3718

+1 650 838 3718

Menlo Park

Kristen Garry

Partner

Tax

+1 202 508 8186

+1 202 508 8186

Washington DC

Jay M. Singer

Partner

Tax

+1 202 508 8117

+1 202 508 8117

Washington DC

Nathan Tasso

Partner

Tax

+1 202 508 8046

+1 202 508 8046

Washington DC

Todd Lowther

Partner

Tax

+1 713 354 4898

+1 713 354 4898

Houston

Michael Shulman

Partner

Tax

+1 212 848 8080

+1 212 848 8080

New York

Derek Kershaw

Counsel

Tax

+1 212 848 7964

+1 212 848 7964

New York

Julia Pashin

Associate

Tax

+1 214 271 5665

+1 214 271 5665

Dallas

Practices

Regional Experience