Daniel Dunn

Daniel Dunn

Dechert LLP

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IRS Issues Proposed Regulations Relating to the Treatment by Regulated Investment Companies of Income from Subsidiaries Investing...

The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more

11/5/2016 - Commodities Internal Revenue Code (IRC) Investment Companies IRS Private Letter Rulings RICs Subsidiaries

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more

10/26/2016 - Capital Expenditures Debt Debt Financing Disguised Sales Final Rules IRS Partnerships Proposed Regulation REIT Reporting Requirements Risk Allocation Tax Structuring U.S. Treasury

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

7/2/2016 - CFCs Controlled Foreign Corporations Corporate Taxes Customs Dividends EEA EU Exit Tax ICAV Income Taxes International Tax Issues Referendums Stamp Taxes Tax Treaty Transfer Pricing UK UK Brexit VAT

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

5/13/2016 - BEPS Capital Gains Double Taxation Foreign Investment India OECD Tax Rates Tax Treaty

New Proposed Regulations Increase Scrutiny on Related-Party Debt

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

4/29/2016 - Debt Equity Partners Income Taxes Inversion IRS Proposed Regulation U.S. Treasury

Partnership Audits of Private Equity Firms on the Rise

There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

4/1/2016 - Audits Bipartisan Budget Business Taxes IRS Management Fees Partnerships Private Equity Firms

Navigating the New Partnership Audit Rules: Sea Change or Same Course?

The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more

2/2/2016 - Audits Bipartisan Budget Internal Revenue Code (IRC) IRS Operating Agreements Partnerships

Protecting Americans from Tax Hikes Act of 2015 Approved by Congress and Signed by the President

President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more

12/28/2015 - FIRPTA Internal Revenue Code (IRC) IRS Popular Protecting Americans from Tax Hikes (PATH) Act REIT RICs

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more

8/17/2015 - Business Taxes Fee Waivers IRS Management Fees Partnerships Profits Interests Safe Harbors Significant Entrepreneurial Risk (SER) Treasury

Publicly Traded Partnership Proposed Regulations

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

6/24/2015 - Corporate Taxes Double Taxation Energy Projects Energy Sector Fracking Internal Revenue Code (IRC) IRS Limited Partnerships Master Limited Partnerships Mining Natural Gas Oil & Gas Partnerships Passive Activity Proposed Regulation Publicly-Traded Companies Qualifying Income Research and Development

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more

3/13/2015 - Corporate Taxes Double Taxation Funding Internal Revenue Code (IRC) IRS Mineral Exploration Oil & Gas Partnerships Private Letter Rulings Publicly-Traded Companies

The New Landscape for Inversions: IRS and Treasury Change the Rules

The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more

10/1/2014 - Controlled Foreign Corporations Corporate Taxes Cross-Border Foreign Subsidiaries IRS Multinationals U.S. Treasury

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more

10/11/2013 - Banks DOJ EU Foreign Bank Accounts Non-Prosecution Agreements Non-Target Letters Tax Evasion Voluntary Disclosure

OECD Sets Out Ambitious Global Plan to Tackle Tax Fairness Issues

The Organisation for Economic Co-operation and Development (OECD) issued an “Action Plan” to tackle “Base Erosion and Profit Shifting” (“BEPS”) on 19 July 2013. The concept of BEPS covers a range of international tax...more

7/24/2013 - Enforcement Actions Fairness Hearings G20 OECD Tax Rates Tax Reform

Private Equity - Winter/Spring 2013

In This Issue: - ILPA Guidelines Have Noticeable Impact - Extracting Tax Value in Debt Refinancings and Modifications - Private Equity and Venture Capital Investing in China: Exit Strategy and Circular 698 -...more

4/29/2013 - Private Equity Private Equity Funds Venture Capital

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