The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier version of this bill was passed by the US House of Representatives on May 22, 2025 (the “House version”). Our prior Legal
MB Microtalk: Excise Tax
In this MB Microtalk video, Mayer Brown’s Brennan Young discusses the stock buyback excise tax, and its impact on various types of transactions.
Visit our MB Microtalk page for more topics and talks.
US Inflation Reduction Act – Corporate Minimum Tax and Stock Repurchase Excise Tax
If you thought the recent price increase at your neighborhood store was inflation’s last flop, think again. The Inflation Reduction Act (“IRA”), which was signed into law by President Biden on August 16, 2022, is estimated to raise $739 billion over the decade. The IRA is financed primarily by several targeted tax increases. Revenues will
US IRS Releases Final Regulations Addressing IBOR Transition
On December 30, 2021, the Internal Revenue Service (IRS) published final regulations for the IBOR transition. This Legal Update provides background on the principle US federal income tax concern with IBOR-related amendments to existing contracts and an overview of previous IRS guidance aimed at addressing the concern. The Update then discusses the types of modifications
Limited US Tax Guidance for Adding ARRC and ISDA Fallbacks
On Friday, October 9, 2020, the Internal Revenue Service released Revenue Procedure 2020-44 (the “Revenue Procedure”), providing retroactive but limited relief for amending specific types of legacy contracts to add fallback mechanics for the London Interbank Offer Rate or other Interbank Offer Rates. The fallback granted relief by the Revenue Procedure must rather strictly follow
Debt Restructuring During the COVID-19 Pandemic – Key Tax Considerations
Businesses are under unprecedented stress due to the global COVID-19 pandemic. Many of these businesses need some form of relief on their debt obligations in order to avoid triggering defaults, foreclosures and collection activity during this extraordinary period of economic inactivity. There is no one way to structure a workout. The workout structure can be