Todd Lowther

Dec 28, 2023 | lexology.com | Larry Crouch |Ryan Bray |Todd Lowther |Jay Singer |Matthew Brown |José Germano Rego | +1 more

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”).[1] The Treaty provides for reduced withholding tax rates on income such as dividends, interest and royalties with the goal of reducing double taxation and increasing commerce and investment between the United States and Chile.

Jul 7, 2023 | law360.com | Jorge Medina |Todd Lowther |Mona Dajani

By Jorge Medina, Todd Lowther and Mona Dajani (July 7, 2023, 5:35 PM EDT) -- On June 14, the U.S. Department of the Treasury and the Internal Revenue Service released highly anticipated guidance relating to new Internal Revenue Code Section 6418, which was added as part of the Inflation Reduction Act to provide taxpayers an alternative to monetize certain tax credits.... Stay ahead of the curveIn the legal profession, information is the key to success.

Jul 7, 2023 | law360.com | Jorge Medina |Todd Lowther

By Sign up now By Jorge Medina, Todd Lowther and Mona Dajani ·On June 14, the U.S. Department of the Treasury and the Internal Revenue Service released highly anticipated guidance relating to new Internal Revenue Code Section 6418, which was added as part... To view the full article, register now.

May 28, 2023 | mondaq.com | Ryan Bray |Larry Crouch |Todd Lowther |Gillian Emmett Moldowan

On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner1 holding that the taxpayer's indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event under the safe harbor provided in Rev. Proc. 93-27.2 The opinion provides a well-reasoned application of the profits interest safe harbor that puts to rest certain unsettled tax issues relating to the use of such structures.