Kristen Hazel

Kristen Hazel

McDermott Will & Emery

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Treasury Releases Guidance for Contributions of Appreciated Property to Partnerships with Related Foreign Partners

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more

8/25/2015 - Capital Gains Cost-Sharing Foreign Corporations Intangible Property IRC IRS New Guidance New Regulations Partnerships Property Transaction Taxes U.S. Treasury

Focus on Tax Strategies & Developments - June 2015

In This Issue: - Distinguishing Between Captive Insurance and Related Party Derivatives: Chief Counsel Advice Memorandum 201511021 - Achieving Tax-Free ‘Rollover’ Treatment for Certain Shareholders in Acquisition of...more

6/23/2015 - Captive Insurance Company Corporate Restructuring Foreign Currency IRS Transfer Taxes

International News: Focus on International Private Client

In This Issue: Features - ..The UK Response to BEPS and Hybrid Mismatches ..Parental Liability for French Subsidiaries ..The Evolving US-Cuba Trade Landscape ..Amendments to Taiwan Fair...more

4/10/2015 - BEPS Cuba Foreign Investment Foreign Subsidiaries France Taiwan Trade Relations UK

IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies as Insurance for Federal Tax Purposes

On May 18, 2014, the Internal Revenue Service (IRS) ruled that an employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax...more

6/2/2014 - Captive Insurance Company Healthcare IRS Medical Benefits Reinsurance Retirement

Inside M&A - Winter 2014

Delaware Court of Chancery Upholds Forum Selection Bylaws - In recent years, virtually every merger and acquisition (M&A) transaction of significant size involving a U.S. public company has been challenged in court. ...more

2/20/2014 - Board of Directors Corporate Taxes Shareholder Litigation Shareholders

IRS Office of Chief Counsel Treated Collaboration Arrangement as Partnership

In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more

6/10/2013 - Drug Manufacturers FDA IRS Joint Venture Partnerships Supervision and Collaboration Agreements

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