The Internal Revenue Service recently issued proposed regulations under Section 956 of the Internal Revenue Code (IRC) that may allow foreign subsidiaries of U.S. multinational corporate borrowers to provide additional
Continue Reading IRS Issues Proposed Section 956 Regulations Relating to Foreign Subsidiary Guarantees and Stock Pledges

Chang Won Choi
Chang Choi focuses his practice on U.S. federal tax matters, with an emphasis on domestic and cross-border mergers and acquisitions, partnership transactions, tax-free spin-offs and other capital market transactions. He has wide-ranging experience representing and advising private equity sponsors in connection with leveraged buy-outs, joint ventures, initial public offerings of portfolio companies, fund formations and structuring matters.
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GT Alert – Highlights of the Tax Cuts and Jobs Act
By Chang Won Choi, David Dalton, Marvin A. Kirsner, James O. Lang, Noam Lipshitz, Paul B. McCawley, William R. Siegel, Robert D. Simon, Kevin Zaragoza & Diana Zeydel on
Posted in Congress, Estate Planning, Estate Tax, Government, Income Tax, Tax Planning, Uncategorized
On Dec. 20, 2017, the House and Senate passed the Tax Cuts and Jobs Act, H.R.1, and this bill is on its way to President Trump for signature. When signed into…
Continue Reading GT Alert – Highlights of the Tax Cuts and Jobs Act