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"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

"Key Takeaways: Corporate Governance Series — Key Trends in Executive Compensation, Employment Law and Compensation Committee...

On February 28, 2017, Skadden hosted a webinar titled “Key Trends in Executive Compensation, Employment Law and Compensation Committee Practices.” The Skadden panelists were labor and employment law partner David Schwartz,...more

Indonesian feed-in tariffs – New rules may under-power the renewables sector

Indonesia's new feed-in tariffs (FITs) for renewable energy present a conundrum. Will renewables flourish or fade in the new revenue environment? Investors will not welcome the lower tariffs under the new regime, but state...more

IRS Notice: Conservation Easements for Charitable Giving

In Notice 2017-10, the Internal Revenue Service recently issued guidance on syndicated conservation easement transactions presumed to be used as tax shelters. This addition to the “listed transactions” under Section...more

New stamp duties on shares transfer – Acquisition and disposal of equity interests in residential property holding entities

Purchases of residential properties in Singapore by companies attract Additional Buyer Stamp Duty (ABSD) of 15% rate in addition to usual Buyer Stamp Duty (BSD) of up to 3%. Seller Stamp Duty (SSD) is also payable if...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Tax. Major Russian legislation changes for 2016

We would like to present the overview of the most important legislation changes in tax for 2016. Practice of applying the beneficial owner concept develops rapidly. ...more

Practice Pointers: Anticipating and Addressing SEC Comments on Non-GAAP Financial Measures - February 2017

The use of non-GAAP financial measures by public companies continues to be an area of growing concern for the Securities and Exchange Commission (“SEC”). Since the staff of the SEC’s Division of Corporation Finance (the...more

Foreign Investment in Australia

Foreign investment is key to Australia’s economic development, and Australia welcomes it. As the fourth largest economy in the dynamic Asia Pacific region, Australia's competitive economy is set for continued expansion...more

Ukraine: New rules on withholding tax for Eurobond offerings and LPNs

Starting from January 1, 2017 Ukrainian tax legislation contains new (more favorable) rules on taxation of interest payable by Ukrainian borrowers under Eurobonds offerings relating to LPN structures. It is common for...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

Shareholder Liability For Corporate Income Tax?

Limited Liability - In general, the creditors of a corporation cannot recover the corporation’s debts from its shareholders—the shareholders enjoy the benefit of limited liability protection as a matter of state law....more

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. ?11-6602/2016 (the “Decision”) under the claim of Vladimir Energy RetailCompany1 Public Joint-Stock Company (the “Company”)....more

Alberta Investor Tax Credit: Alberta introduces a new investor tax credit aimed at small business

On January 16, 2017, the online application portal for the Alberta Investor Tax Credit (AITC) opened to Alberta small businesses seeking to benefit from the recently introduced AITC and it will remain open until the 2017...more

The Basics of 1031 Exchanges – Part Two: Structuring Partnership/LLC 1031 Exchange Cash-out Transactions

This is part two of a two-part series on Internal Revenue Code Section 1031 tax-deferred exchange transactions. The first article provided an overview of the basic rules that govern 1031 exchanges. This article describes...more

Alert: Year-End Reporting for ISOs and ESPPs

This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to incentive stock option exercises and transfers of stock...more

Reminder: Information Statements Due by January 31, 2017, for 2016 Incentive Stock Option and Employee Stock Purchase Plan...

This is a reminder to public and private companies that grant incentive stock options (“ISOs”) or maintain a tax-advantaged employee stock purchase plan (“ESPP”) of certain year-end reporting requirements....more

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

California Court of Appeal Holds Doing Business ? Any Activity Engaged In for Pecuniary Gain

On January 12, 2017, the California Court of Appeal held in a published opinion that a taxpayer passively holding a 0.2 percent interest in a California-based limited liability company (CA LLC) was not “doing business” in the...more

Executive Compensation Alert: IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers

This Client Alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the “Code”), with respect to stock issued to employees (or former...more

Rollover Equity in the Sale of a Family-Owned Business

If you sell your family-owned business to a private equity buyer, the buyer will most likely pay a portion of the purchase price with equity in the buyer’s new company, rather than with cash. The equity that you receive in...more

Applying the Look-Through Rules in Determining 'Investment Partnership' Status Under Section 721(b) - Tax Update Volume 2017,...

Careful Evaluation and Planning Should Be Undertaken When the Partnership Is Formed and When Assets Are Contributed to Evaluate the Potential Impact of Section 721(b). Many taxpayers choose partnership structures...more

Transfer pricing rules to change in Ukraine from 2017

On December 21, 2016, the Verkhovna Rada of Ukraine approved in the second reading the Draft Law "On Amending the Tax Code of Ukraine (on the Improvement of Investment Climate in Ukraine )" No. 5368. The law has been sent to...more

Renewable Energy Investor Group Asks FERC to Designate Certain Passive Equity Interests in Public Utilities as “Non-Voting...

On December 9, 2016, a group of investors in renewable energy projects (“Petitioners”) asked the Federal Energy Regulatory Commission (FERC) to find that certain non-managing (i.e., passive) “tax equity” interests in public...more

RESTRUCTURING A MULTINATIONAL CORPORATION TO OPTIMIZE EFFICIENCY AND PROFITABILITY

Attached is a free, downloadable case study (with diagrams) on the strategic, legal, tax and regulatory aspects of the implementation of a "Swiss Principal" model global restructuring for a U.S.-based industrial and...more

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