Jeffrey Sion

Jeffrey Sion

Dechert LLP

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Final US Treasury Regulations Provide Additional Flexibility in Determining the Tax Implications of Money Market Fund Share...

Final U.S. Treasury regulations under Section 446 of the Internal Revenue Code of 1986, as amended (the “Code’), providing for the use of the net asset value (“NAV”) accounting method for transactions in money market fund...more

7/26/2016 - Accounting Methods Excise Tax Final Rules Floating NAV Income Taxes Internal Revenue Code (IRC) Investment Company Act of 1940 IRS Money Market Funds NAV SEC U.S. Treasury

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

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

An Appreciation for Hedging Your Bets on Deferred Compensation

Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more

8/19/2014 - Deferred Compensation Equity Compensation Internal Revenue Code (IRC) Investment Funds IRS Offshore Companies SAR Section 457A

An Appreciation for Hedging Your Bets on Deferred Compensation: IRS Issues Revenue Ruling 2014-18 Under Section 457A of the...

Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more

6/13/2014 - Deferred Compensation Equity Compensation Executive Compensation Internal Revenue Code (IRC) Investment Funds IRS Private Equity Funds SAR Section 457A Stock Options Tax Planning

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