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General Business Finance & Banking Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

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

by Dechert LLP on

CSSF Press Release 17/06 Dated 13 February 2017 - The CSSF confirmed that it follows ESMA on its opinion in relation to the requirements for UCITS share classes....more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part II

by Farrell Fritz, P.C. on

Aside from planning for the taxation of U.S.-sourced rental income, the foreigner must plan for the disposition of the USRP pursuant to a sale. The taxation of gain realized by a foreigner on the sale of an interest in...more

Delaware Proposes Unclaimed Property Regulations – No April Fools

by McDermott Will & Emery on

On Saturday, April 1, 2017, the Delaware Department of Finance (DOF) promulgated two regulations that would repeal all existing unclaimed property regulations and replace them with a single DOF regulation containing a revised...more

“Path to Marijuana Reform” Legislation Introduced in Congress

by Tucker Arensberg, P.C. on

On March 30th, bipartisan U.S. lawmakers introduced a package of three marijuana reform bills collectively being called the “Path to Marijuana Reform” aimed to “pave the way for responsible federal regulation of the legal...more

Brussels Regulatory Brief: April

by K&L Gates LLP on

On 13 March 2017, it was announced that a United States (“U.S.”) chipmaker will acquire an autonomous vehicle technology company based in Israel for approximately USD 15.3 billion. This transaction may provide an interesting...more

Corporate E-Note - March 2017

by Burr & Forman on

Burr & Forman recently defended the contract manufacturer XYMOGEN, Inc. in a federal jury trial involving a $16,000,000 lost profits claim by a disgruntled former customer. Please see full E-Note below for more...more

FDIC Chairman: A “Culture of Compliance” Begins at the Top

by Ballard Spahr LLP on

In his remarks during last week’s launch of Case Western Reserve School of Law’s Financial Integrity Institute, FDIC Chairman Martin J. Gruenberg spoke on the historical context of today’s BSA/AML regulatory framework and the...more

IRS Synchs Excise Tax to DOL's Enforcement Policy on Fiduciary Rule

by Burr & Forman on

The IRS released guidance this week announcing that it will not apply IRC § 4975 excise taxes (15% on prohibited transactions) and related reporting requirements “with respect to any transaction or agreement to which the...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The struggle to attract and retain businesses and the jobs they provide has increasingly led to states and cities squaring off against others, with competing tax incentive packages the very real currency of the battle....more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

by Foley & Lardner LLP on

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Funds Bulletin - February 2017

by Hogan Lovells on

Funds Bulletin (a monthly round-up of topical legal, regulatory and tax issues affecting the fund industry). Features our summary of the FSCP's position paper on the impact of Brexit on financial services consumers, as well...more

Protecting Tax Deferral for A Contribution to A Partnership

by Farrell Fritz, P.C. on

When a taxpayer (“Taxpayer”) sells a property (“Property”) with a fair market value (“FMV”) in excess of Taxpayer’s basis in Property in exchange for cash in an arm’s-length transaction, the amount of gain that he realizes on...more

Singapore Eases Regulatory Regime for VC Funds to Promote Financing for Start-Ups

by Morgan Lewis on

The Monetary Authority of Singapore has proposed a simplification of the authorisation process and regulatory framework for venture capital managers—with the goal of supporting start-ups....more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

by Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Former AIG chief Hank Greenberg and his co-defendant, AIG’s former CFO, reached an “unexpected” settlement last week with NY officials. The duo will fork over about $10 million in bonuses payments and admit that they...more

The Blockchain revolution: An analysis of regulation and technology related to Distributed Ledger Technologies

by DLA Piper on

Blockchain is on the verge of revolutionizing how we interact in the digital world. It has far reaching applications from the Financial industry to many other sectors of the economy. The question is what is Blockchain, what...more

"Trump’s Proposed Changes to Tax, Dodd-Frank, DOL Could Impact Executive Compensation"

President Donald Trump’s campaign proposals included changes to tax rates and a promise to repeal the Dodd-Frank Act. If enacted, these proposals could have a significant impact on the way businesses handle executive...more

The New Issue Price Regulations: The Good, the Bad and the Ugly

by Bracewell LLP on

Late last year, the Treasury Department released final Treasury Regulations (the “New Regulations”) relating to the “issue price” of tax-exempt bonds, effective for bonds sold after June 7, 2017. Because the changes imposed...more

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

Rolling Over Target Equity Into A PE Fund: Part I

by Farrell Fritz, P.C. on

For many business owners, the final step of a successful career may be the sale of their business. At that point, the investment into which the owners have dedicated so much time, effort and money is liquidated, leaving them...more

New Belgian Crowdfunding Law: Requirements and Tax Benefits

by McGuireWoods LLP on

The Belgian Law of 18 December 2016 on crowdfunding will enter into force on 1 February 2017. The crowdfunding law creates a specific status for equity and debt crowdfunding platforms (referred to as “alternative...more

Corporate E-Note - January 2017

by Burr & Forman on

The IRS has announced it will begin treating certain syndicated conservation easement transactions and “substantially similar” transactions as “listed transactions.” Notice 2017-20 published on December 23, 2016 (the...more

IRS Clarifies New Management Contract Safe Harbors

In August, 2016, the IRS issued Revenue Procedure 2016-44, the first comprehensive revision of its management contract safe harbors since Revenue Procedure 97-13. Rev. Proc. 2016-44 built upon and amplified principles laid...more

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