General Business Finance & Banking Tax

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Fifth Circuit Holds that Loss on Abandoned Securities is Ordinary Loss

Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more

Hong Kong Government to Extend Existing Offshore Funds Tax Exemption to Private Equity Funds

The Hong Kong government has announced in its latest budget a planned extension of the existing offshore funds tax exemption to bring offshore private equity funds investing in or through Hong Kong, within its scope. The...more

Tax Policy Update

NUMBER OF THE WEEK: $160,000. The value of one gift bag at the Oscars on Sunday night. According to the Internal Revenue Service, contents of the gift bags cannot be treated as gifts for federal income tax purposes because...more

Accountant and Attorney Liability Newsbrief - Winter 2015

In This Issue: - The Affordable Care Act and CPAs: It Takes a Village - U.S. District Court for District of Massachusetts Holds Testator’s Attorney Can Be Held Liable to A Beneficiary - New Jersey...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

CSSF Reminder Regarding Nomination of Depositaries of Bearer Shares - The Luxembourg regulator for the financial services industry (CSSF) has issued a press release and a FAQ in relation to the immobilization of bearer...more

Spotlight on Tennessee: Proposed Revenue Modernization Act

Governor Haslam's Administration has very recently proposed far-reaching amendments to Tennessee's tax laws. These proposed amendments are included in Senate Bill 603/House Bill 644, known as the Revenue Modernization Act...more

Insurance Topics We Will Be Watching in 2015

With the first month of the year behind us, this report outlines major insurance topics that we will be watching throughout 2015. Forces, trends and events that we believe will affect regulation, transactions and...more

China's Tax Administration Issues New Rules Governing Taxation of Offshore Indirect Transfers

On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident...more

Is a Distribution of Previously Taxed Income “Exempt from Tax”?

A U.S. shareholder of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of the CFC’s subpart F income and/or the amount determined under Section 956 with respect to such...more

Favorable German tax regime for partnership-type AIFs expanded

The German Federal Ministry of Finance has recently issued guidance that broadens the favorable tax regime for investment partnerships applicable to closed-end alternative investment funds (AIFs). The following Dechert...more

New York State Division of Tax Appeals Renders Long-Awaited Decision Regarding Corporate Franchise Tax Sourcing of Services and...

For years, both the New York State Department of Taxation and Finance (the “Department”) and the New York City Department of Finance have aggressively sought to classify receipts generated by electronic or online service...more

Sound Bites from Infocast Wind Finance 2015

The Infocast Wind Power Finance & Investment Summit 2015 was held from February 10 to 12 in San Diego. Below are selected sound bites regarding the tax equity market and other finance related matters....more

Control Transactions in the UK Mid-Market

In a number of transactions in the UK mid-market in which we have been involved recently, we have noted a departure from the traditional private equity buy-out model, whereby the sponsor acquires 100% of the target and...more

The ERISA Litigation Newsletter - February 2015

The Supreme Court cast a ray of sunlight for employers by rejecting the use of a problematic inference in adjudicating claims for retiree benefits brought pursuant to collective bargaining agreements. For many years, the...more

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

Tax Newsletter - November/December 2014 (China & Hong Kong)

Editorial Note: Welcome to the latest issue of our Tax Newsletter. A number of developments have taken place in the PRC and Hong Kong that could be of legal and tax significance to your businesses. In the PRC, the...more

The President’s Groundhog’s Day Budget Casts a Shadow on Some but Offers Sunshine for Others

On February 2nd, President Obama released his Fiscal Year (FY) 2016 budget request to Congress. Along with the budget, the Department of the Treasury (Treasury) released a volume called “General Explanations of the...more

Delaware Enacts Unclaimed Property Legislation That Addresses Some (But Not All) Holder Concerns

The Delaware Legislature appears to have heard some of the complaints of the unclaimed property community. Delaware Governor Jack Markell signed Senate Bill 11, which is based on the recommendations of the Delaware Task Force...more

Banking Corporation Not Required to Hypothetically Use New York NOL Deduction When Tax Is Paid on Asset Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in Matter of TD Holdings II, Inc., DTA No. 825329 (N.Y. Div. Tax App. Jan. 22, 2015), that a banking corporation is not required to...more

Five Facts about the Proposed UK Diverted Profits Tax

The UK government has proposed its "diverted profits tax" in order "to counteract contrived arrangements used by large groups (typically multinational enterprises) that result in the erosion of the UK tax base." There follows...more

French Finance Act for 2015 and Amending Finance Act for 2014: Key Tax Measures for Corporations

The French Finance Act for 2015 and Amending Finance Act for 2014 were enacted on December 30, 2014 (the “Acts”). The Acts introduce a new penalty for failure to comply with French transfer pricing requirements, and a...more

European Commission extends State aid probe into Belgian tax scheme

The European Commission (“Commission”) has opened a fifth formal State aid investigation into national tax rulings. This investigation concerns the Belgian “excess profit” provision, which allows multinational groups to...more

"Unlocking Value Through REIT Spin-Offs"

Real estate investment trust (REIT) spin-offs provide a means for companies to unlock the value of their real estate. Due to current economic conditions, more companies in more business sectors are considering separating...more

IRS Will Not Follow Partner COD Bankruptcy Exception Cases

In a new Action on Decision (AOD 2015-10), the IRS stated that it will not follow the Tax Court’s 2004 Martinez decision, which had allowed a general partner to exclude cancellation of debt (COD) income from a partnership in...more

OSC Expects REIT Distributions Disclosure to Yield More Information

In the current low interest rate environment, yield-hungry investors have been particularly attracted to real estate investment trusts (REITs), which, as tax-efficient, flow-through investment vehicles, aim to pay regular...more

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