Robert Clary II

Robert Clary II

McDermott Will & Emery

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Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

11/12/2014 - Corporate Taxes FATCA Income Taxes Inversion Mortgages Real Estate Market REIT Spinoffs Subpart F Tax Structuring

Focus on Private Equity - July 2014

In This Issue: - Latin American Private Equity on the Rise - Tax Considerations When Acquiring Non-U.S. Portfolio Companies—Mitigating Subpart F Inclusions - Private Equity Funds at Higher Risk of...more

7/18/2014 - Antitrust Investigations International Tax Issues Latin America Private Equity Subpart F

Courts Continue Literal Interpretation of Subpart F Rules on Income Inclusion

Consistent with prior judicial precedent, the U.S. Court of Appeals for the Fifth Circuit recently applied a literal interpretation of the Subpart F inclusion rules based on the plain meaning of Sections 951 and 956....more

7/18/2013 - Income Taxes Plain Meaning Statutory Interpretation Tax Reform

Inside M&A - Spring 2013

Top Five Traps for the Unwary in Spin-Offs - A wave of corporate breakups has swept through the United States over the last few years as investors have taken notice of the fact that smaller companies focused on a...more

4/30/2013 - Disclosure Requirements Employee Benefits Incentives Private Letter Rulings Restructuring Separate Accounts Separation Spinoffs Tax Exemptions

‘Fiscal Cliff’ Legislation Temporarily Extends Key Provisions for Businesses

As part of legislation enacted in early 2013 to avert the so-called “fiscal cliff,” Congress temporarily extended several beneficial tax provisions for businesses, including the research credit, the active financing exception...more

1/7/2013 - American Taxpayer Relief Act Business Taxes Capital Gains Dividends Fiscal Cliff Foreign Corporations Income Taxes S-Corporation Tax Exemptions Tax Incentives

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