Securities General Business Tax

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Your daily dose of financial news The Brief – 11.20.15

The US Treasury Department and IRS are joining forces to address corporate tax inversions with the introduction of new measures aimed at “curtailing companies’ ability to avoid United States tax rates if they move to...more

Be Cautious of Late In the Year Mutual Fund Purchases

This is the time of year to be cautious about buying a mutual fund. Many funds pay dividends near the end of the calendar year in December. If you buy one now, and it pays a dividend, you will be paying taxes for 2015 on the...more

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the "Reports") after a two-year consultation period during which 62 countries and many other stakeholders (such as...more

Where We Stand on Issue Price for Tax-Exempt Bonds

The U.S. Treasury Department and the Internal Revenue Service (IRS) held a public hearing on the definition of issue price for tax-exempt bonds on October 28, 2015. The hearing is another step in the process of changing what...more

The Acquisition and Leveraged Finance Review

During the decade preceding the financial and economic crisis, Austria has developed into a buoyant market for both domestic and international M&A activity, with some of the peak years seeing over 400 deals. Compared to...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Vesting 101 – Whaddya Mean I Don’t Own My Stock?

Vesting is an extremely important concept that arises (or should) among the founders when a company is formed, when equity incentives are granted and when outside investors invest. Although some founders view vesting as yet...more

Employee Benefits Developments - October 2015

The Internal Revenue Service (IRS), consistent with prior regulations from the Department of Health and Human Resources (HHS), issued supplemental proposed regulations requiring employer sponsored health plans to provide...more

US Withholding Tax on Dividend Equivalent Payments Under Swaps

The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on swaps and other financial instruments that are linked to US equities. These...more

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

ALFI releases FAQs on RQF II - Further to the announcement by the People’s Bank of China on 29 April 2015 of a RMB 50 billion Qualified Foreign Institutional Investor (“RQFII”) quota being granted to Luxembourg, the...more

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

New Treasury Regulations Make it Easier to Issue Tack-On Bonds or Loans

On September 12, 2012, the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) which make it easier to issue fungible tack-on debt instruments in situations where either the original debt...more

IRS Provides Guidance on Fund of Funds

On September 15, the Internal Revenue Service published final regulations revising examples related to the application of the controlled group rules to regulated investment companies (RIC) and how the controlled group rules...more

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

IRS Addresses RIC Asset Diversification Requirements

On September 14, the Internal Revenue Service (IRS) issued final regulations under Internal Revenue Code Section 851 clarifying that control groups under the regulated investment company (RIC) rules may consist of two...more

IRS Adds Certain Spin Transactions to the “No Rule” List

Treasury and IRS announce that certain “cash rich” and REIT/RIC conversion spin-offs are under study and are added to the “no rule” list. On September 14, 2015, the United States Treasury Department (the Treasury) and...more

Corporate and Financial Weekly Digest - Volume X, Issue 37

SEC/CORPORATE - SEC Advisory Committee on Small and Emerging Companies Makes Recommendations - On September 23, the Securities and Exchange Commission Advisory Committee on Small and Emerging Companies (Advisory...more

UK tax treatment of US LLCs: HMRC responds to the Supreme Court’s decision in Anson v HMRC

Executive Summary - Her Majesty’s Revenue & Customs (HMRC) has now published its response to the U.K. Supreme Court’s recent judgment in Anson v HMRC. The response confirms that HMRC will continue its existing practice...more

Corporate Alert: The Luxembourg Special Limited Partnership

Largely inspired by the Anglo-Saxon limited partnership regimes, the special limited partnership (SLP) has been designed to bolster Luxembourg’s position as the main alternative investment fund structuring hub in the EU at a...more

Doing Business in Canada

This Guide provides non-Canadians with an introduction to the laws and regulations that affect the conduct of business in Canada and, in particular, in the province of Ontario. In some cases, this Guide also identifies issues...more

FATCA Update: Institute of International Bankers Submits Comment Letter on FATCA Regulations

The Institute of International Bankers (IIB) has submitted a comment letter (available through Bloomberg BNA here; subscription required) to the Internal Revenue Service addressing various issues arising under the FATCA...more

The Treasury and the IRS Issue Spin-Off Revenue Procedure and Notice Announcing No-Rule Areas That Are Under Study

On September 14th, the IRS released Rev. Proc. 2015 43 (the “Rev. Proc.”) announcing new “no-rule” areas with respect to spin offs involving substantial amounts of investment assets, small amounts of active trade or business...more

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

Pension Investment Management Services - with or without VAT?

A significant cost of running a defined benefit pension scheme historically has been the VAT on investment management services. However, HMRC has recently confirmed that a European court case means employers may now recover...more

Altera: Tax Court Invalidates Section 482 Regulation on Administrative Law Grounds

In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm’s-length...more

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