A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets.
This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength.
Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations.
Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
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.
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).
Originally published 22 August, 2020
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
