Business Organization Finance & Banking Tax

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Corporation or LLC? Business Organizations for Tech Startups.

One of the first actions you will take with your startup is to organize your company a separate legal entity to protect yourself from personal liability for the company’s debts. In the tech startup context, you’ll typically...more

Tax Review - August 2015

We are proud to present the next edition of our “Tax Review” which contains a selection of rulings and interpretations that had been issued or published in July 2015. We hope you will find the information provided here...more

Cyprus and Iran sign Double Tax Treaty

On 4 August 2015, the governments of Cyprus and Iran signed an agreement for the avoidance of double taxation (the Treaty). With the lifting of international sanctions against Iran, Cyprus is now uniquely positioned to act as...more

The Essential Plan Providers For A 401(k) Plan

When people are sick, especially debilitating illnesses or diseases, it’s natural for them to travel far and wide to get the best medical coverage possible. I live in Long Island, but my children were born in Manhattan...more

Pensions News - July 2015

Welcome to DLA Piper’s Pensions News publication in which we report on developments in pension legislation, guidance and case law, as well as keeping you up to speed on what to look out for in the coming months. This...more

Successful Strategies for Doing Business in Asia: Korea (Updated)

WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more

Absurd Things About 401(k) Plans That Are True

We drive on parkways and park on driveways. Cigarettes are sold in gas stations even though smoking is prohibited there. Fat chance and slim chance mean the same thing. Phonetic isn’t spelled the way it sounds. When it comes...more

Proposed Regulations Require Significant Entrepreneurial Risk for a Service Partner's Income to be a Distributive Share

On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A) (the proposed regulations) which would treat certain partnership...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Tax Proposals in Summer 2015 Budget to Affect UK Asset Managers - The UK Summer Budget was announced on 8 July 2015, and included a number of unexpected tax proposals affecting the UK asset management industry, including...more

Successful Strategies for Doing Business in Asia: Japan (Updated)

WHAT ROLE WILL THE GOVERNMENT OF JAPAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Generally speaking, foreigners can conduct business in Japan on an equal legal footing with Japanese citizens. The...more

A UK home for private funds? HM Treasury consults on potential amendments to United Kingdom limited partnership legislation

HM Treasury has published a consultation paper setting out proposed reforms to UK limited partnerships law with a focus on private fund structures (the “Consultation Paper”). The consultation includes a draft legislative...more

Special Session Ends with Handful of Noteworthy Tax Bills, Predictions for Next Special Session

The first Special Session of 2015 ended on Tuesday, August 11, without accomplishing the primary objective of passing a General Fund budget for the 2015-2016 fiscal year. The Governor’s “call” for the special session included...more

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

FBAR Deadlines Not as Close as You Think: New Tax Bill's Language Points to 2017 as Likely Timetable

Thank you for your interest in the 5th Annual IRS Hot Topic Seminar held in Jerusalem in July. In continuing our efforts to provide timely and extremely important updates on tax matters affecting U.S. citizens and green card...more

IRS Announces Intent to Tax Transfers to Partnerships

On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"),[1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more

There Is No Such Thing as Free 401(k) Administration

There is no such thing as the Easter Bunny, or the Tooth Fairy, or the Boogeyman. While we can laugh at it, it’s surprising to note that many plan sponsors still believe they pay nothing for 401(k) plan administration even in...more

Successful Strategies for Doing Business in Asia: India (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF INDIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Historically, India has been a regulated economy since its independence. The government of India (GOI) launched a new...more

Treasury Imposes Toll Charge on Some Transfers of Assets by U.S. Taxpayers to Partnerships with Their Foreign Affiliates

On August 6, 2015, the Treasury and the IRS issued Notice 2015-54, which implements a Clinton-era tax provision intended to prevent U.S. taxpayers from using the partnership provisions of the Code to shift built-in gain on...more

Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event. On August 6, the US Treasury...more

Ninth Circuit: Multiemployer Plan Calling Unpaid Contributions “Plan Assets” Does Not Make Persons Controlling Contribution...

The Ninth Circuit recently held that a multiemployer pension plan (MEP) cannot label unpaid contributions as “plan assets” so as to impose ERISA fiduciary status on persons controlling the payment of employer contributions to...more

Attention 401(k) Plan Sponsors: This is Your Wake Up Call

Anytime I travel, I ask for a wake up call even though my IPhone will blare “Eat the Rich” by Aerosmith at the same time because you can never be too careful. When I travel around the country to speak, I want to make sure I...more

Is An Asset Purchaser Liable For Seller’s Withdrawal Liability?

Many asset buyers believe that, as long as they do not agree to ERISA Section 4204’s sale of assets exception to withdrawal liability, they will acquire the seller’s assets free and clear of any prior contribution history and...more

Successful Strategies For Doing Business In Asia: Hong Kong (Updated)

Hong Kong is always rated as one of the world’s freest economies, one of the reasons being that the government has always adopted the approach of nonintervention. Hong Kong strives to attract more foreign investors to...more

On-Line Fundraising, Some Tax Implications

Many have participated in, or know someone who has launched, a “Kickstarter” campaign or other online means of securing funds for a project. Others may have encountered a request for contributions to a “fund” for some tragic...more

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