Securities Tax

Read need-to-know updates, commentary, and analysis on Securities issues written by leading professionals.
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Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Luxembourg Infrastructure Investment Vehicles - New Brochure - The Association of the Luxembourg Fund Industry (ALFI) has issued new technical guidelines regarding “Luxembourg Infrastructure Investment Vehicles”,...more

Australian Employee Share Schemes - More options to share...

From tomorrow, the way in which new employee share scheme awards will be taxed in Australia has changed and for the better. Following on from recent changes to assist companies to meet their corporate compliance obligations,...more

Financial Services Quarterly Report - Second Quarter 2015: Countdown to 1 July 2015: Accessing China and Australia via Hong Kong’s...

On 1 July 2015, two significant developments in the Asian funds space will come into effect. Hong Kong’s Mutual Recognition of Funds Scheme (MRF) with the PRC will – for the first time – allow international managers to...more

Treasury Revises Issue Price Regulations

The Treasury Department published in the June 24, 2015 Federal Register new proposed regulations for determining the “issue price” of bonds. The same announcement also withdrew the proposed regulations published in 2013 (the...more

IRS Revamps Proposed Issue Price Definition for Municipal Bonds

Treasury and IRS today announced a decision to withdraw the much-criticized portion of the notice of proposed rulemaking published in the Federal Register on September 16, 2013 (the “2013 Proposed Regulations”) related to the...more

New Regulations Address Treatment of Corporate Partners with Appreciated Partnership Interest

After much promise, the IRS issued two sets of regulations to address the potential avoidance of gain by corporate partners. First, new § 337(d) temporary regulations, often referred to as the “May Company” regulations,...more

Ticking all the Right Boxes! Irish Collective Asset Management Vehicles Act 2015 Signed into Law

The eagerly anticipated Irish Collective Asset-management Vehicles Act 2015 (the “ICAV Act”) was signed into law in March 2015 and the first Irish Collective Asset-management Vehicles (“ICAVs”) have been authorised by the...more

Orrick's Derivatives in Review - June 2015

NYDFS Finalizes BitLicense Regulations - On June 3, 2015, the New York Department of Financial Services released its final BitLicense regulations, which it described as "the first comprehensive framework for regulating...more

$228 Million: The Cost of Independent Contractor Misclassification for FedEx Ground in California

Yesterday, June 12, FedEx announced in papers filed with the SEC that its Ground Division “has reached an agreement in principle with [drivers] in the independent contractor litigation that is pending in …California [federal...more

New York’s Highest Court Considers Constitutionality of Retroactive Taxing Statute

Questioning the constitutionality of state personal income tax provisions seems to be all the rage these days. On the heels of the Supreme Court’s decision in Comptroller v. Wynne discussed in our recent blog post, New York’s...more

Kruger: FX Derivatives Gains/Losses Taxed Only When Realized

In Kruger Incorporated v. The Queen (2015 TCC 119), the Tax Court held that the taxpayer could not value its foreign exchange options contracts on a mark-to-market basis, with the result that certain losses were not...more

Nowotny on Private Placement Group Variable Deferred Annuity Contracts for Tax Exempt and Foreign Investors [Video]

The Private Placement Group Variable Deferred Annuity Contract aka GAC has quietely been used by tax-exempt organizations for some time. As far as I can count, $50 billion of tax exempt transactions have utilized the GAC as a...more

Nowotny on Private Placement Variable Deferred Annuities [Video]

I have written previously on the use of private placement variable annuities in trust planning. I call the idea -Dynasty Annuity. the fact of the matter is that no grantor of a Grantor Trust is happy paying taxes on income...more

Income Tax & Crowdfunding

Income tax may not be front of mind when starting a crowdfunding campaign, but early consideration of the issues could prevent a panic-inducing call from the Australian Taxation Office. The choice of crowdfunding model...more

Nowotny on Private Placement Life Insurance [Video]

This is the first in what will hopefully of a series of videos on private placement insurance products and planning. This is a topic of increasing interest and popularity with high net worth clients and their advisors. My...more

Launch of Mutual Recognition of Funds Between Mainland China and Hong Kong

On 22 May 2015, the Securities and Futures Commission of Hong Kong (SFC) and the China Securities Regulatory Commission (CSRC) signed a Memorandum of Regulatory Cooperation on Mainland-Hong Kong Recognition of Funds, which...more

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

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

First Marblehead Requests U.S. Supreme Court Review In SINAA Sourcing Appeal

In a case of interest for any taxpayer with substantial securitization activities, First Marblehead Corporation and Gate Holdings, Inc. have requested United State Supreme Court review of a recent determination of the...more

Bureau of Economic Analysis (BEA) Form BE-10 Extension Until June 30, 2015

The BEA has posted on its website that the filing deadline for all “new filers” for the BE-10 (which is the five year benchmark survey of United States direct investment abroad) has been extended to June 30, 2015. A new filer...more

Canada's Resource Revenue Transparency Rules Now in Force

Canada's new Extractive Sector Transparency Measures Act was proclaimed in force today, in keeping with the federal Government's committed timeline. The Act imposes mandatory reporting requirements for each entity engaged in...more

Proposed Regulations on Publicly Traded Partnerships Affect Natural Resource Industry

The IRS proposed regulations [REG-132634-14] to provide guidance on what is “qualified income” from a publicly traded partnership’s (PTP) activities regarding minerals or natural resources, such as oil and gas fracturing...more

IRS Presses Pause on Issuing Rulings

The IRS announced earlier this week that it may temporarily stop reviewing private letter ruling requests on the issue of whether a spin-off qualifies as tax-free under Section 355. More specifically, the IRS may hit pause on...more

Uses of Suspicious Activity Reports by the IRS

In a recent conference the Director of the Financial Crimes Enforcement Network (FinCen) discussed the use of Currency Transaction Reports (CTR's) and Suspicious Activity Reports (SAR's) which are required to be filed by...more

New Temporary and Proposed Regulations Offer Welcome Clarification on Application of the Embedded Loan Rule

On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC §§ 446 and 956 (T.D. 9719; REG-102656-15), clarifying when nonperiodic payments made pursuant to...more

The Best of a Bad Investment

A recent tax case out of the Fifth Circuit approved a taxpayer’s strategy to make the best of a bad investment. According to the facts of Pilgrim’s Pride v Commissioner, the taxpayer purchased preferred stock from two...more

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