Securities Tax

Read need-to-know updates, commentary, and analysis on Securities issues written by leading professionals.
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Estate Planning Pitfall: You’re donating high-basis stock to charity

As the end of the year approaches, many may begin thinking about making gifts to qualified charitable organizations as a way to reduce potential estate and income tax liability while supporting a worthy cause. This brief...more

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

Impact Investing and Private Foundations

Bryan Cave recently organized a half-day symposium examining the opportunities and legal considerations related to responsible and impact investing strategies. The Responsible and Impact Investing Symposium, held on November...more

Employee Benefits Developments - November 2016

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November, 2016. ACA Information Reporting – Bad News and Good News - First, the bad news: The 2016 final...more

U.K. Autumn Statement 2016: Key Implications for Investment Funds

On Wednesday 23 November 2016, Philip Hammond delivered the U.K. Autumn Statement, which included a number of announcements of relevance to the financial services industry. While relatively few new tax measures were...more

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

Central Bank launches ORION II platform to authorise all QIAIFs applications - All QIAIFs applications (including ICAVs) will be processed via the CBI’s ORION platform allowing consistency with other legal structures and...more

UK Autumn Statement 2016: finance

In the 2016 Autumn Statement, the UK government confirmed, as previously announced, that from April 2017, it is to cap the amount of tax deductions for interest to the higher of 30% of taxable earnings in the UK or the net...more

UK Autumn Statement 2016

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

Globally Taxing Issues for Private Equity

Tax has, in recent months, become a frontpage issue with reaction to businesses not “paying their fair share” sitting alongside pressure on government finances and an uncertain political environment. In our view, the...more

The IRS and Courts Weigh in on the Deductibility of Fines and Penalties - Tax Update, Volume 2016, Issue 3

Taxpayers who make payments in conjunction with a forfeiture action should attempt to understand the characterization of a payment to see if the specific payment can avoid being treated as a fine or penalty. Originally...more

Trump Risk Factors Begin to Appear in SEC Documents

Risk factors related to uncertainties resulting from possible policies that may be implemented by President-elect Trump have begun to appear in SEC filings...more

Quick Guide to REIT IPOs - 2016

Real Estate Investment Trusts (“REITs”) are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to hold interests in real estate. The REIT market has waxed and waned over the...more

ERISA Basics National Institute: Section 401(k) Plans

A 401(k) plan has a qualified cash or deferred arrangement that is part of a profit sharing plan or stock bonus plan. Under the Internal Revenue Code Section 401(k)(2), an employee may elect to make contributions to the plan,...more

Examining the Impact of the 2016 US Elections on Executive Compensation

Will it soon be time to chart a new course in executive compensation? As a result of the November 8, 2016 election, Republicans will control the Presidency, the Senate and the House of Representatives beginning on...more

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware...more

Private equity’s top ten issues for the next president

Many of the issues on the next President’s plate have unique resonance within the private equity world. Here is our list of the top ten private equity issues that the new President and Congress may tackle in the upcoming...more

IRS Issues Proposed Regulations Relating to the Treatment by Regulated Investment Companies of Income from Subsidiaries Investing...

The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more

Renewed Perils from “Zeroing Out” a Corporation at Year-End

Physicians who are involved in the financial management of their practices are all too familiar with the year-end scramble to “zero out” the corporation’s profits. Under this technique, a physician practice that is structured...more

The annulment of the CIT exemption for closed-end investment funds

On 31 October 2016, a Bill on the amendment to the Personal Income Tax Act and the Corporate Income tax Act was submitted to the Sejm. The Bill provides, among others, for modified principles of taxation for investment funds,...more

Impact of New Tax Regulations on Intercompany Debt Obligations

The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more

PIK Toggles Are Back: Uncertainty for AHYDO Savings and Catch-Up - Volume 2016, Issue 4

Issuers and their advisors need to be aware of the potential pitfalls and uncertainties of the applicable high-yield discount obligation rules, which can have the effect of permanently disallowing a portion of interest...more

When a 'Business Expansion' Can Satisfy the Active Trade or Business Requirement in Section 355 Distributions - Volume 2016, Issue...

The active trade or business rules are detailed and highly fact specific, and the IRS continues to refine its view on the qualification requirements. In order to separate two businesses housed in one corporation or in a...more

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Stock Acquisitions Checklist

On October 22, 2016, the Treasury finalized the debt/equity regulations under Section 385 it had proposed in April. The 517-page package can daunt even the most motivated readers. “Expanded groups” (EG) that know they will be...more

Lower taxes on Italian new-residents | Insights | DLA Piper Global Law Firm

The Italian Government has released a number of proposals in the Draft Budget Law aimed at encouraging international High Net worth individuals to live and invest in Italy. These include easier entry visas for foreign...more

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