Adam Tejeda

Adam Tejeda

K&L Gates LLP

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The 336(e) Election: Possible Deemed Asset Sale Treatment When a 338(h)(10) Election is Unavailable

For U.S. federal income tax purposes, a purchaser in a corporate acquisition typically prefers to acquire assets of a target corporation (“Target”) rather than stock because a purchaser that acquires assets is able to “step...more

11/1/2013 - Acquisitions Asset Transfer Income Taxes Section 336(e) Stock Deals Tax Planning

FATCA Regulations Finally Arrive: A First Look

On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more

1/23/2013 - FATCA FFI Foreign Banks Foreign Financial Accounts Intergovernmental Agreements IRS NFFE

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