Stephen Lessard

Stephen Lessard

Orrick, Herrington & Sutcliffe LLP

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IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

3/3/2017 - AbbVie Capital Losses Inversion IRS Offshore Companies Pharmaceutical Industry Shareholder Votes Stocks Tax Liability Tax Planning Tax Rates Termination Payments

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

2/2/2017 - Consumer Financial Products Derivatives Dividend-Equivalent Transactions Exchange-Traded Products Financial Markets Financial Sector Internal Revenue Code (IRC) IRS Master Limited Partnerships Partnerships Qualified Derivatives Dealers (QDDs) Section 871(m) Securities SIFMA Stocks

IRS Releases Transition Guidance for the Dividend Equivalent Rules

On December 2, 2016, the Internal Revenue Service (the “IRS”) issued Notice 2016-76 (the “Notice”), which provides highly anticipated guidance regarding “dividend equivalent” payments under section 871(m) of the Internal...more

12/13/2016 - Dividend-Equivalent Transactions Dividends IRS Qualified Derivatives Dealers (QDDs) Section 871(m) Withholding Tax

100% Exclusion for Gains from Qualified Small Business Stock Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

12/18/2015 - C-Corporation Capital Gains Gain Exclusion Qualified Small Business Stock Tax Liability

IRS Announces Intent to Tax Transfers to Partnerships With Foreign Partners

On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more

11/24/2015 - Corporate Taxes Foreign Affiliates IRS Partnerships Transfer of Assets

Orrick's Derivatives in Review - June 2015

NYDFS Finalizes BitLicense Regulations - On June 3, 2015, the New York Department of Financial Services released its final BitLicense regulations, which it described as "the first comprehensive framework for regulating...more

6/16/2015 - BitLicense CFTC Department of Financial Services Derivatives End-Users IRS Mandatory Clearing Requirements Payment Schedules SEC Securitization Security-Based Swaps SPVs Trade Options

IRS Scripts a New Tune with Final Whistleblowing Regulations

Section 7623 of the Internal Revenue Code (the “Code”), added in 1954, authorizes the Treasury Secretary to pay an award as he deems necessary for “(1) detecting underpayments of tax, or (2) detecting and bringing to trial...more

9/4/2014 - Anti-Retaliation Provisions Internal Revenue Code (IRC) IRS U.S. Treasury Whistleblower Awards Whistleblowers

New York State Corporate Tax Law Reform: The Impact on Companies Providing Digital Products

On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime (the "Act"), most notably for out-of-state corporations providing digital products to New...more

7/31/2014 - Corporate Taxes Digital Assets Franchise Taxes Popular State Taxes Tax Reform

IRS Issues Temporary Regulations on the Application of the Straddle Rules to Debt Instruments

On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more

10/16/2013 - Debt Foreign Currency IRS

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