Administrative Agency Securities Tax

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Did the IRS Just Help or Hurt the Bitcoin Economy?  [Video]

Apr. 1, 2014 -- Houman Shadab, Associate Professor at New York Law School, talks with Lee Pacchia about recent developments in the bitcoin economy....more

Investing In Georgia: Economic Development Newsletter - August 2013

Welcome to King & Spalding's economic development news bulletin, Investing in Georgia. In this edition, you will find: - A Client Alert regarding recent SEC enforcement actions againsta School District - A new...more

N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

A New York administrative law judge recently held in Matter of C.V. Starr & Co., Inc. that income received by a taxpayer from its ownership of common stock was investment income. In so holding, the ALJ addressed an important...more

Congress Extends Exclusion for Investors in Qualified Small Businesses

Among the taxpayer-favorable aspects of the American Taxpayer Relief Act of 2012 (Act), the 100 percent exclusion from gross income of gain on the sale of Qualified Small Business Stock (QSBS), provided for in section 1202 of...more

Annual Notices for ISOs and ESPPs due January 31, 2013

Each January, companies that grant incentive stock options (ISOs) are required to provide notices to current and former employees who exercised ISOs during the preceding calendar year. Similar notices must be given to current...more

FinCEN Announces Third Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

Investment Management Legal + Regulatory Update -- December 2012

In This Issue: Regulatory Updates - FSOC, FSB Turn Up Heat on SEC on Money Market Fund Reforms; SEC Staff: Beware of BDC Joint Transactions; SEC Reports 3,000 Whistles Blown in FYI 2012; Over 1500 Private Fund Advisers...more

Foreign Taxpayers Can Benefit Despite Proposed Regulations

Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more

MoFo New York Tax Insights - Volume 3, Issue 12 - December 2012

In This Issue: Court Holds Television Programming Is Included in the Property Factor Regardless of Delivery Method; ALJ Upholds Retroactive Application of Stock Option Regulations; Petition Found Untimely Under Special...more

CFTC Issues First Set of Mandatory Clearing Determinations and Time-Limited No-Action Relief

On November 28, the Commodity Futures Trading Commission (CFTC) issued final clearing determinations (Final Determinations) with respect to four classes of interest rate swaps (IRS) and two classes of credit default swaps...more

Financial Services Quarterly Report - Third Quarter 2012

In This Issue: - Commodity Pool Operators and Commodity Trading Advisers: Practical Advice for Fund Managers Outside the United States p. 1 - Recent Developments in the Regulatory Framework of the PRC Investment...more

IRS Issues Final Treasury Regulations Expanding Definition of "Traded on an Established Securities Market" and Liberalizing Rules...

On September 12, 2012, the Internal Revenue Service (the “IRS”) issued Final Treasury Regulations (the “Final Regulations”) that clarify the circumstances that cause property to be treated as “traded on an established market”...more

Final U.S. Regulations Clarify When Property Is Deemed Publicly Traded for Purposes of Determining the Issue Price of a Debt...

The Internal Revenue Service (IRS) has issued final regulations clarifying when property will be considered publicly traded for purposes of determining the issue price of a debt instrument. The determination of the issue...more

Private Funds In Focus - Fall 2012

In This Issue: - I Want You To Want Me – Achieving a Successful First Closing - SEC Proposes Rule Amendments To Permit General Solicitation in Private Offerings - STOCK Act Presents New Compliance Concerns...more

Would $104 Million IRS Whistleblower Get Stiffed Under Dodd-Frank?

The recent announcement that the IRS granted a $104 million whistleblower award to convicted former UBS banker Bradley Birkenfeld generated front-page news coverage. Birkenfeld, the U.S.-bred former private banker who...more

Determining the Issue Price of a Debt Instrument: Final Treasury Regulations Clarify When Property Is Publicly Traded

On September 12, 2012, the US Internal Revenue Service (the “Service”) released final regulations (the “Final Regulations”) detailing when property is publicly traded for purposes of determining the issue price of a debt...more

"Treasury Promulgates Final Regulations on Publicly Traded Debt Instruments"

On September 12, 2012, the Department of the Treasury (Treasury) promulgated important final regulations (the Regulations) that clarify and expand the circumstances in which a debt instrument is to be treated as traded on an...more

IRS Amends Temporary Treasury Regulations under Section 871(m)

On August 31, 2012, the U.S. Internal Revenue Service (the “IRS”) amended Temporary Treasury Regulations (the “Temporary Regulations”) under Section 871(m) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”),...more

Hong Kong Capital Markets Quarterly News -- July 2012

In This Issue: SFC Notes Poor Quality Listing Applications; Regulation of Sponsors in Hong Kong; Class Action Reform; New Listing Decisions; New Guidance Letters; Enforcement News; and Regulatory Watch. Excerpt...more

Financial Services Quarterly Report - Second Quarter 2012

In This Issue: - DIFC Funds: A New Investment Vehicle for the Middle East p. 1 - An Analysis of the EU and U.S. Regulations Affecting OTC Derivatives p. 4 - Enhancing the Investment Advisory Contract Review...more

Startup Act 2.0 – Making The 100% QSB Stock Exemption Permanent

Good news for startups. A bill has been introduced in the Senate (S.3217) and an identical bill has already been introduced in the House, titled Startup Act 2.0 which, among other things, would make the 100% exclusion from...more

CJEU Ruling in Santander: Withholding Tax on Dividends Distributed to Non-Resident UCITS Infringes EU Freedoms

On 10 May 2012, the Court of Justice of the European Union (CJEU) issued its judgment in Santander (joined cases C-338/11 to C-347/11), stating that the French legislation that imposes a withholding tax on French-sourced...more

Hybrid Securities: An Overview

Originally published in the Practical Law Company Multi-Jurisdictional guide 2012/13: Capital Markets. The history of hybrid securities may well be divided into two periods: pre-financial crisis and post-financial...more

Proposed Tax Changes in India may have a significant impact on International Investors

On March 16, 2012, India’s Finance Minister presented the country’s budget for the fiscal year beginning April 1, 2012, which included proposed legislation that seeks to reverse the decision of (India’s) Supreme Court in the...more

FinCEN Issues Additional Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts have until June 30, 2013, to file the FBAR. On February 14, the Financial Crimes Enforcement Network (FinCEN) announced that...more

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