Daniel Dunn

Daniel Dunn

Dechert LLP

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Latest Publications


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 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 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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