Michael Shulman

Michael Shulman

Shearman & Sterling LLP

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The Treasury and the IRS Issue Spin-Off Revenue Procedure and Notice Announcing No-Rule Areas That Are Under Study

On September 14th, the IRS released Rev. Proc. 2015 43 (the “Rev. Proc.”) announcing new “no-rule” areas with respect to spin offs involving substantial amounts of investment assets, small amounts of active trade or business...more

9/17/2015 - IRS Real Estate Investments REITS Revenue Procedure 2015-27 Revenue Procedure 2015-28 Spinoffs U.S. Treasury

Is It All Now Transparent? UK Supreme Court Case on Delaware LLCs Leaves Open Questions on Entity Classification for UK Tax...

The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 44. Reversing the decisions of the Upper Tribunal...more

7/7/2015 - Corporate Taxes HMRC Limited Liability Companies Tribunals UK UK Supreme Court

United States and Brazil Sign FATCA Intergovernmental Agreement

The United States and Brazil have signed a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”). The Brazilian IGA is intended to simplify FATCA information...more

10/1/2014 - Brazil FATCA IGAs International Tax Issues Tax Evasion

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

9/25/2014 - Corporate Taxes International Tax Issues Inversion IRS Tax Evasion U.S. Treasury

FATCA: Implications for Non-US Funds

A general guide in determining the application of FATCA to non-US funds. I. What Is FATCA? FATCA refers to the US Foreign Account Tax Compliance Act (contained in Sections 1471 through 1474 of the US Internal Revenue...more

5/28/2014 - FATCA Income Taxes International Tax Issues Offshore Funds Tax Evasion

New Proposed Regulations Under Section 871(m) Adopt a Single Factor Test but Delay Effective Date Until 2016

On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

12/9/2013 - Delays Financial Regulatory Reform Income Taxes IRS Swaps U.S. Treasury

United States Signs FATCA Intergovernmental Agreement With the Cayman Islands

The US Department of the Treasury recently announced that the United States has signed a “Model 1” intergovernmental agreement (an “IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”) with the Cayman...more

12/9/2013 - FATCA IGAs

Cayman Islands Government Announces FATCA Intergovernmental Agreement

The Cayman Islands government announced on August 13, 2013 that it has concluded negotiations with the US government on a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act...more

8/22/2013 - Compliance FATCA Intergovernmental Agreements Tax Reform TIEA

Timeline for Initial FATCA Implementation Extended

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more

7/16/2013 - Delays FATCA FFI Foreign Banks IGAs IRS U.S. Treasury

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