Securities Tax

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IRS Proposed Regulations Under Section 305(c)

In April, the IRS issued proposed regulations interpreting deemed distributions under Section 305(c). Specifically, the proposed regulations would clarify the amount and timing of deemed distributions that result from an...more

Practice Pointers on the Up-C Structure

In a structure commonly referred to as an “up-C,” an existing limited liability company or other partnership form (referred to here for convenience as “LLC”) undertakes a public offering through a newly formed corporation,...more

IRS Offers Tax Guidance Relating to Money Market Fund Rules

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

Launching a Hedge Fund in 2016: An Overview for US Managers

Despite a challenging environment for the hedge fund industry, many institutional investors continue to allocate to hedge funds in a market environment otherwise devoid of promising investment opportunities. While the hedge...more

Georgia Angel Investment Tax Credit

In Georgia, start-ups and new businesses are often able to attract investors, in part, because of Georgia’s “angel tax credit” program. Georgia’s angel tax credit program provides early investors in certain start-ups and new...more

Global Tax News: US Treasury's proposed §385 regulations under extreme scrutiny on Capitol Hill, in corporate tax departments: top...

As part of its ongoing effort to try to curb inversion transactions, the Treasury Department has issued proposed regulations under section 385. Section 385(a) authorizes the Treasury Department to issue regulations that may...more

Tax Treaty Savings Clause Question

Facts: A U.S. citizen and permanent resident of Israel incurs capital gains from the sale of stock of a U.S. corporation. U.S. - Israel Income Tax Treaty Provisions: Article 15, Paragraph 1: “[a] resident of one of...more

Legislation Revives and Permanently Extends 100% Gain Exclusion for Certain Sales of (C Corporation) Qualified Small Business...

For years now, conventional wisdom has been that, wherever possible, businesses should seek to operate as flow through entities (S corporations or partnerships) for income tax purposes. One rationale for this viewpoint has...more

UK Financial Regulatory Developments - May 2016 #9

Chancellor responds on tax deductibility of regulatory fines - The Chancellor has responded to a letter from Andrew Tyrie MP, Chairman of the Treasury Committee, to confirm that payments made by banks to regulators are...more

UK Financial Regulatory Developments - May 2016 #8

FCA announces insider dealing convictions - FCA has announced two convictions in the case it brought as part of Operation Tabernula. Martyn Dodgson, an investment banker, and Andrew Hind, a property developer and...more

Attention Taxpayers: New IRS Rules May Deem Debt to Be Stock

In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes. These rules would apply to all corporations (including regular C corporations, S corporations, foreign...more

IRS Guidance Regarding Money Market Mutual Funds

On July 23, 2014, the Securities and Exchange Commission adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended, governing the structure and operation of money market mutual funds (MMFs). ...more

Justice Department’s First FATCA Prosecution Yields Guilty Plea

On May 9, 2016, the Justice Department announced that Gregg R. Mulholland, a dual U.S. and Canadian citizen and owner of an offshore broker-dealer and investment management company based in Panama and Belize, pleaded guilty...more

That Debt Isn’t What You Think It Is: New Proposed Debt/Equity Rules Could Be Biggest Change in Corporate Tax Since 1986

The U.S. Treasury Department issued new proposed tax regulations that would re-characterize certain related party debt as equity, resulting in dividend payments rather than tax deductible interest payments. If finalized in...more

FASB modifies accounting rules for stock-based compensation

The Financial Accounting Standards Board (FASB) has issued Accounting Standards Update (ASU) 2016-09, Improvements to Employee Share-Based Payment Accounting, which amends ASC Topic 718, Compensation – Stock Compensation. ...more

Carried Interest: Belgian Ruling Commission Confirms Application Of Stock Option Law

The Belgian Stock Option Law sets out the tax treatment of stock options, thereby eliminating the uncertainty as to the taxable value of the stock options. In the past, the Belgian Ruling Commission has been reluctant to...more

IRS Notice Offers Relief to Issuers of Variable Insurance Products in Response to Pending Money Market Fund Reforms

On May 5, 2016, the IRS issued Notice 2016-32, 2016-21 I.R.B. 1, which affords relief with respect to the application of the diversification requirements of IRC § 817(h) to variable life insurance and annuity contracts...more

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

Start Up India: Opportunities for investors and entrepreneurs

On 16 January this year, Prime Minister Narendra Modi announced the “Start-up India Action Plan” (“Action Plan”). The Action Plan is the latest in Modi’s moves to revive the Indian economy and generate employment, and follows...more

US targets the use of LLCs to disguise foreign beneficial owners

The United States Department of Treasury issued proposed regulations that, if promulgated, would impose new disclosure obligations on domestic disregarded entities wholly owned by foreign persons (i.e., single-member limited...more

Your daily dose of financial news The Brief – 5.10.16

Big news out of the online lending space, as Lending Club’s chair and CEO—Renaud Laplanche—has resigned after an internal review “showed a violation of the company’s business practices” related to sales of $22 million in...more

"Key Takeaways: Changes Will Impact Investment in US Real Estate"

On May 4, 2016, Skadden presented the seminar “How FIRPTA and REIT Changes Will Impact Investment in US Real Estate.” Congressman Joseph Crowley, D-N.Y., gave the introductory remarks, and panelists included Jeffrey DeBoer,...more

Compensation and Benefits Insights – April 2016

Private Equity Funds Found Liable for Portfolio Company’s ERISA Withdrawal Liability - The most recent ruling in the ongoing Sun Capital Partners III, LP v. New England Teamsters and Trucking Industry Pension Fund case...more

MoFo Tax Talk - Volume 9, No. 1

IRS Publishes Proposed section 305(c) Regulations - On April 12th, the IRS published proposed regulations under Section 305(c) that address the treatment of deemed dividends to holders of stock and rights to acquire...more

New Collective Investment Vehicles

This week's Federal Budget ushered in a new era in investment management in Australia with the announcement that the Federal Government will introduce a new tax and regulatory framework for two new types of collective...more

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