Daniel Dunn

Daniel Dunn

Dechert LLP

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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 IRS Mineral Exploration Oil & Gas Partnerships Private Letter Rulings PTPs Publicly-Traded Companies Section 7704

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 Inversions IRS Multinationals Notice 2014-52 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 - ILPA Guidelines Private Equity Private Equity Funds Venture Capital

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