Mergers & Acquisitions, Administrative Law, Tax Law

Administrative Law Judge Affirms Holding on Alabama SRLY Rule

by Christopher Grissom, James Long | Bradley Arant Boult Cummings LLP on 2/26/2013

On August 15, 2012, Chief Administrative Law Judge Bill Thompson issued his long-awaited SRLY ruling, holding that an Alabama consolidated group was entitled to carry forward certain net operating losses (“NOLs”) incurred...more

State and Local Tax Implications of Reorganizing Business Enterprises

by Morrison & Foerster LLP on 8/2/2012

Originally published in State Tax Notes, July 23, 2012. This is the first installment in a series that will examine state and local tax (SALT) questions implicated by the purchase, sale, and reorganization of business...more

Getting The Deal Through - Mergers & Acquisitions 2012 - Cyprus

by Harney Westwood & Riegels on 6/21/2012

"Reproduced with permission from Law Business Research Ltd. This article was first published in Getting the Deal Through – Mergers & Acquisitions 2012, (published in May, 2012; contributing editor: Casey Cogut, Simpson...more

The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings

by Sutherland Asbill & Brennan LLP on 6/13/2012

On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final, temporary, and proposed regulations under section 7874, which provides rules governing so-called “inversion transactions.” In...more

Baker & McKenzie: 2012-13 Federal Budget: Spreading the benefits of the boom...but not to foreign investors

by Baker & McKenzie Australia on 5/9/2012

The Treasurer has delivered the 2012-13 Budget. As part of a concerted effort to ensure a budget surplus (of $1.5 billion), the promised company tax cuts have been scrapped and the tax burden for foreign investors has been...more

The 2011 Form 990: More than Simple Tinkering at the Margins

by McDermott Will & Emery on 2/7/2012

While recent changes to the Form 990 make it more reader friendly, filing organizations must carefully review it for substantive changes to determine the impact on their reporting requirements, particularly tax-exempt...more

Recent Compensation Trends In Mergers And Acquisitions And Section 409a

by Orrick, Herrington & Sutcliffe LLP on 10/31/2011

This article discusses the traps for the unwary created by Section 409A of the Internal Revenue Code (“Section 409A”) with respect to current trends in change-in-control compensation for public company executives and the...more

Understanding the difference between: Limited Liability Partnerships (LLP) and Private Limited Company (Pvt. Ltd.)

by iPleaders and Intelligent Legal Risk... on 9/6/2011

Since LLP has been introduced in India, apart from incorporating a traditional Limited Liability Company, it has become an option for entrepreneurs, business owners and investors starting new ventures to start their business...more

Killer B Regulations Finalized

by Charles (Chuck) Rubin on 7/11/2011

Triangular B reorganizations are often conducted whereby a subsidiary corporation will acquire a target corporation in exchange for stock of the subsidiary’s parent corporation. Throw a foreign corporation into the mix and...more

Update: New IRS Reporting Rules for Stock Splits, Mergers and Acquisitions

by Sheppard Mullin Richter & Hampton LLP on 3/16/2011

Update: The IRS recently came out with a Notice (Notice 2011-18) stating that, for transactions occurring in 2011, penalties will not be imposed against issuers for missing the deadline to file a return or post the tax...more

New Tax Reporting Requirements For Corporate Actions Affecting Stock Tax Basis

by Wilson Sonsini Goodrich & Rosati on 1/14/2011

Beginning on January 1, 2011, regulations1 issued under Section 6045B of the Internal Revenue Code will require any domestic or foreign corporation that undertakes an “organizational action,” such as a merger, acquisition,...more

Crisis Commission Argues on IRS Assistance for Wachovia

by Darrin Mish, Tampa Tax Attorney on 9/8/2010

The Financial Crisis Commission has put forth its argument that Wells Fargo & Co’s purchase of Wachovia was with government assistance despite the widely held belief that it was not. The IRS had changed the tax code just...more

Communications Law Bulletin, October 2008

by Morrison & Foerster LLP on 10/30/2008

In this issue: *The Month in Brief *FCC Streamlines Satellite Earth Station License Process *California Passes New Broadband and Prepaid Services Laws and Considers Copper Loop Retirement Issues *FCC Clarifies ?Junk...more