Pamela Lawrence Endreny

Pamela Lawrence Endreny

Skadden, Arps, Slate, Meagher & Flom LLP

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Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

4/22/2014 - Accounting Alternative Minimum Tax Corporate Taxes Debt Restructuring Derivatives Financial Products Foreign Tax Internal Revenue Code Partnerships Subpart F Tax Credits Tax Reform Ways and Means Committee

"Treasury and IRS Release FATCA Regulations"

New Regulations Address Some Concerns and Coordinate FATCA Rules with Other Reporting and Withholding Rules - On February 20, 2014, the Department of the Treasury and the IRS issued a comprehensive set of final and...more

3/13/2014 - FATCA IGAs IRS U.S. Treasury

"Financial Institutions Wrestle With FATCA Implementation"

Over the past year, financial institutions have wrestled with the challenges presented by the U.S. Foreign Tax Compliance Act (FATCA). Originally scheduled to take effect in 2013, the U.S. Treasury Department and IRS have...more

1/29/2014 - Banks FATCA HIRE Act IRS Offshore Funds Tax Evasion

"IRS Releases Final and Proposed Regulations Regarding Dividend Equivalent Payments to Foreigners"

As part of 2010 legislation, Congress enacted section 871(m) of the Internal Revenue Code, which provides that payments made to foreign persons under specified notional principal contracts (“Specified NPCs”), securities...more

12/16/2013 - Compliance Corporate Counsel Corporate Taxes Dividends Foreign Nationals IRS

"Treasury and IRS Move to Implement FATCA as 2014 Start Date Approaches"

On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010 as part of...more

11/5/2013 - Deadlines FATCA HIRE Act IRS Tax Evasion U.S. Treasury

"New FIRPTA Reform Would Attract Foreign Investment in US REITs"

Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more

8/1/2013 - FIRPTA Foreign Investment Income Tax Treaty Investment Portfolios REIT

"First Circuit Holds That a Private Equity Fund May be Liable for Portfolio Company Pension Obligations"

On July 24, 2013, the U.S. Court of Appeals for the First Circuit held that a private equity fund sponsored by Sun Capital Advisors constituted a “trade or business” for purposes of ERISA multiemployer pension withdrawal...more

7/30/2013 - Controlled Groups ERISA Multi-Employer Pensions Pensions Private Equity Private Equity Funds Sun Capital Partners

"House Ways and Means Proposal Would Change the Tax Treatment of Partnerships and S Corporations"

The first congressional proposals to revamp partnership and S corporation taxation in connection with anticipated tax reform have surfaced. Framed as two alternatives, both options suggest significant, and, in the case of one...more

3/29/2013

"House Ways and Means Committee’s Tax Reform Proposals for Financial Products"

On January 24, 2013, Rep. Dave Camp (R-Mich), the chairman of the House Ways and Means Committee, released a “discussion draft” of a bill relating to the taxation of derivatives and other financial products (the Discussion...more

1/29/2013 - Debt-Relief Industry Derivatives Discussion Draft Market Discount Rules Restructuring Wash Sale Rules Ways and Means Committee

"Treasury and IRS Finalize Highly Anticipated FATCA Regulations"

On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more

1/25/2013 - Due Diligence FATCA Intergovernmental Agreements IRS U.S. Treasury Withholding Tax

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