Gary Mandel, Andrew Purcell and Sophie Staples Co-Author Chapter in Tax Series Special Update: Tax Practice After the Tax Cuts and Jobs Act
Tax Partners Gary Mandel and Andrew Purcell and Tax Associate Sophie Staples co-authored a chapter in Tax Series Special Update: Tax Practice After the Tax Cuts and Jobs Act, a special supplement to PLI’s Corporate and Partnership Tax Practice series focused on recent tax reform. The chapter, titled “Cross-Border Acquisitions Following the Tax Cuts and Jobs Act,” highlights tax considerations under the Tax Cuts and Jobs Act relevant to negotiating and structuring acquisitions of foreign corporations by domestic acquirers, specifically the financing of foreign acquisitions following the enactment of the new Section 163(j) limitation on interest deductibility, reforms relating to the repatriation of cash from foreign corporate subsidiaries and the application of the new “global intangible low-taxed income” regime. The chapter will also be published in the 2018 Corporate Tax Practice series.