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Business Organization Tax Securities

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Milan proposes an attractive tax regime – interplay with existing Italian tax rules and some key points

by DLA Piper on

In the international competition for investors and multinationals, Italy has emerged as a contender. Now the Metropolitan City of Milan has upped the ante, seeking to provide its own incentives to attract more investments...more

Italy Addresses "Carried Interest" Tax Treatment

by Jones Day on

The Italian government has enacted Law Decree no. 50 ("Decree 50"), providing a set of new tax measures aimed at, among other things, attracting investments in Italy. Decree 50 was finally approved by the Italian Parliament...more

Valuation of Illiquid Portfolio Investments – Avoiding Regulatory Risks with Form and Substance

For private fund managers, the valuation of privately-held securities has been subject to heightened regulatory scrutiny. As the IPO on-ramp for private “unicorn” investments has lengthened, fund managers may hold illiquid...more

In Case You Missed It: Launch Links - June, 2017

by WilmerHale on

Some interesting links we found across the web this week: HBO’s ‘Silicon Valley’ Tackled an Issue That’s all too Familiar to Startups: The Threat of Frivolous Patent Litigation - The threat of frivolous patent...more

MoFo New York Tax Insights - Volume 8, Issue 6

by Morrison & Foerster LLP on

Judge Dismisses $2.4 Billion False Claims Act Suit Brought Against Citigroup - A New York State Supreme Court Judge has dismissed a qui tam False Claims Act (“FCA”) suit brought by Eric Rasmusen, an economics professor at...more

Compliance With the ERISA Fiduciary Advice Rule for Private Investment Fund Managers and Sponsors and Managed Account Advisers:...

The DOL's "fiduciary advice rule" (the "Rule") will take effect on June 9, 2017. The DOL has published FAQs on the implementation of the Rule applicable to the period between June 9th and December 31st (the "Transition...more

In Securities Fraud Case, Prosecutors Allege Novel Money Laundering Scheme To Circumvent FATCA Reporting Obligations

by Fox Rothschild LLP on

The U.S. Attorney’s Office for the Eastern District of New York has charged four individuals with securities fraud conspiracy for their involvement in fraudulently manipulating the stock of a U.S. company using a traditional...more

Structured Thoughts: News for the financial services community, Volume 8, Issue 5

Implementing the DOL Fiduciary Rule - Background - On June 9, 2017, key provisions of the fiduciary rule adopted by the Department of Labor (“DOL”) will become applicable for most broker-dealers, as well as many...more

News Round Up - May 2017

by Morrison & Foerster LLP on

Reviving the U.S. IPO Market - A recent study based on work undertaken by the University of Florida found that the median age of companies going public in the United States in 1999 was 5 years. Between 20042016, the...more

Let’s Just Fess Up and Agree, Loans are Dodgy Things:  FASB’s New Growth Killing Rule on Loan Losses

by Dechert LLP on

Just when you thought it was safe to go out at night again, another reason not to deploy capital is slouching into Bethlehem. We’ve written a lot here at CrunchedCredit about the Damian-like progeny of Dodd-Frank and Basel,...more

Illinois Senate passes "privilege tax" – deadline for final action is today

by DLA Piper on

The Illinois Senate has passed SB 1719, which would impose a 20 percent "privilege tax" on fees earned by partnerships and S corporations engaged in the business of conducting "investment management services."...more

Holding Defendants' Knowledge Of Potential Tax Issues Subject To Disclosure Under Item 303, Southern District Of New York Denies...

by Shearman & Sterling LLP on

On May 23, 2017, Judge Victor Marrero of the United States District Court for the Southern District of New York denied in part and granted in part a motion to dismiss a putative securities class action against Inovalon...more

IRS Will Resume Ruling on Important Spin-Off Issues

by Jones Day on

The IRS recently provided taxpayers with favorable guidance involving tax-free spin-offs. First, the IRS will resume issuing private rulings that allow a distributing corporation to satisfy debt it issued in anticipation of a...more

ESOP Trends in the Marketplace

by McDermott Will & Emery on

Over the years, employee stock ownership plans (ESOP) have evolved in many ways. Currently, ESOP transactions began to resemble traditional M&A transactions including financial structures, warrants and market rate sub-debt....more

Limitation of Corporate Loss Carryforward Affecting Only Particular Share Transfers Declared Unconstitutional

by White & Case LLP on

The Federal Constitutional Court of Germany held that the forfeiture of tax loss carryforwards under Sec. 8c para. 1 sent. 1 CITA is inconsistent with the principle of equal treatment pursuant to German Constitutional Law....more

A Step in the Right Direction: IRS Rules on North-South Spinoffs

The Internal Revenue Service (IRS) recently released guidance on certain “north-south” spinoff transactions. Generally, a “north-south” transaction consists of a transfer of property from a shareholder to a corporation close...more

IRS Issues Guidance on “North-South” Transactions

by Proskauer - Tax Talks on

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

Tax Consequences to U.S. Shareholders of Holding Shares in a Passive Foreign Investment Company or PFIC

by Dorsey & Whitney LLP on

If a non-U.S. corporation (the “Company”) is a “passive foreign investment company” or “PFIC” for any tax year during which a U.S. shareholder owns shares in the Company, certain adverse U.S. federal income tax consequences...more

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

Recent Amendments to the Alberta Investor Tax Credit Program

by Dentons on

The Government of Alberta recently passed Order in Council 135/2017 (the Recent Amendments) which amends the Alberta Investor Tax Credits Regulation (the Regulations) and makes the Alberta Investor Tax Credit (AITC) program...more

Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings on Certain Spin-Off Debt Exchanges

by Shearman & Sterling LLP on

The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

Public Mergers and Acquisitions in Canada 2nd Edition - May 2017

by Bennett Jones LLP on

Canadian public merger and acquisition transactions in 2016 (in-bound and out-bound) comprised over C$400 billion in value with at least one-third of the transactions in Canada being fueled by foreign buyers. The second...more

Australian Federal Budget 2017 - 2018

by DLA Piper on

The Australian Government introduces a new major bank levy, increases the costs for foreign owners of Australian real estate and extends Managed Investment Trust concessions to investment in Affordable Housing from 1 July...more

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