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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Delaware Code Amendments Increase Franchise Taxes for Corporations

Delaware Gov. John Carney recently signed into law amendments to the Delaware Code altering certain fees and franchise taxes charged by the Delaware secretary of state. The most significant of these amendments raises the...more

ESOPs in Iowa Gone Wrong

by Davis Brown Law Firm on

What is an ESOP? An Employee Stock Ownership Plan (ESOP) is an employee benefit plan designed to give company stock to its employees. ...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

by Shearman & Sterling LLP on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Grecian Magnesite: Tax Court Finds Reliance on a US Tax Advisor Establishes Reasonable Cause

On July 13, 2017, the Tax Court, in Grecian Magnesite, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. 3 (2017), rejected Internal Revenue Service (IRS) arguments that, in order to establish good faith reliance, the...more

IRS Retirement Plan Guidance Simplifies Pre-Approved Plans and Provides Roadmap for Individually Design Plan Conversion

by Benesch on

In Revenue Procedure 2017-41, the IRS makes significant changes to the procedures that it will use in reviewing and approving “pre-approved” retirement plans. The revenue procedure applies to almost all types qualified...more

Tax Court Rejects IRS’ Position in Rev. Rul. 91-32

Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more

Three Fund Issues That Can Unexpectedly Impact Portfolio Company Investments

by Latham & Watkins LLP on

Increasingly complex fund structures and documentation mean that analysing how potential portfolio acquisitions interact with the fund at the top of any deal structure is more important now than ever. Investor Excuse...more

US Tax Court Exempts Gain on Sale of a Partnership Interest

by Latham & Watkins LLP on

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

Treasury Identifies Significant Regulations Subject to Modification or Repeal

On July 7, 2017, Treasury identified eight significant regulations, including regulations under sections 385 (treatment of certain debt as equity), 752 (partnership liabilities), 367 (outbound transfers of property) and 987...more

Applying Georgia's Angel Investor Tax Credits to Convertible Promissory Notes

by Taylor English Duma LLP on

A friend recently asked if the Georgia Angel Investor Tax Credit program would cover an angel investor’s investment in a start-up’s convertible promissory note. It was a good question because start-ups often raise funds...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Upcoming REITs in Poland

by Dentons on

In May 2017, the Polish Government published the second, improved draft bill introducing Real Estate Investment Trusts (“REITs”) in Poland, following the first one which was announced in October 2016....more

[Webinar] Leveraging to Attain Basis Step-Up; Income Tax Benefits of Losing an FLP Case - July 11th, 12:00pm CT

by Thompson Coburn LLP on

Please join us for a webinar based on Steve Gorin's Second Quarter 2017 newsletter, Gorin's Business Succession Solutions. In this webinar the presenter will discuss that one can use debt to allow property to obtain a...more

Milan proposes an attractive tax regime – interplay with existing Italian tax rules and some key points

by DLA Piper on

In the international competition for investors and multinationals, Italy has emerged as a contender. Now the Metropolitan City of Milan has upped the ante, seeking to provide its own incentives to attract more investments...more

Italy Addresses "Carried Interest" Tax Treatment

by Jones Day on

The Italian government has enacted Law Decree no. 50 ("Decree 50"), providing a set of new tax measures aimed at, among other things, attracting investments in Italy. Decree 50 was finally approved by the Italian Parliament...more

Valuation of Illiquid Portfolio Investments – Avoiding Regulatory Risks with Form and Substance

For private fund managers, the valuation of privately-held securities has been subject to heightened regulatory scrutiny. As the IPO on-ramp for private “unicorn” investments has lengthened, fund managers may hold illiquid...more

In Case You Missed It: Launch Links - June, 2017

by WilmerHale on

Some interesting links we found across the web this week: HBO’s ‘Silicon Valley’ Tackled an Issue That’s all too Familiar to Startups: The Threat of Frivolous Patent Litigation - The threat of frivolous patent...more

MoFo New York Tax Insights - Volume 8, Issue 6

by Morrison & Foerster LLP on

Judge Dismisses $2.4 Billion False Claims Act Suit Brought Against Citigroup - A New York State Supreme Court Judge has dismissed a qui tam False Claims Act (“FCA”) suit brought by Eric Rasmusen, an economics professor at...more

Compliance With the ERISA Fiduciary Advice Rule for Private Investment Fund Managers and Sponsors and Managed Account Advisers:...

The DOL's "fiduciary advice rule" (the "Rule") will take effect on June 9, 2017. The DOL has published FAQs on the implementation of the Rule applicable to the period between June 9th and December 31st (the "Transition...more

In Securities Fraud Case, Prosecutors Allege Novel Money Laundering Scheme To Circumvent FATCA Reporting Obligations

by Fox Rothschild LLP on

The U.S. Attorney’s Office for the Eastern District of New York has charged four individuals with securities fraud conspiracy for their involvement in fraudulently manipulating the stock of a U.S. company using a traditional...more

Structured Thoughts: News for the financial services community, Volume 8, Issue 5

Implementing the DOL Fiduciary Rule - Background - On June 9, 2017, key provisions of the fiduciary rule adopted by the Department of Labor (“DOL”) will become applicable for most broker-dealers, as well as many...more

News Round Up - May 2017

by Morrison & Foerster LLP on

Reviving the U.S. IPO Market - A recent study based on work undertaken by the University of Florida found that the median age of companies going public in the United States in 1999 was 5 years. Between 20042016, the...more

Let’s Just Fess Up and Agree, Loans are Dodgy Things:  FASB’s New Growth Killing Rule on Loan Losses

by Dechert LLP on

Just when you thought it was safe to go out at night again, another reason not to deploy capital is slouching into Bethlehem. We’ve written a lot here at CrunchedCredit about the Damian-like progeny of Dodd-Frank and Basel,...more

Illinois Senate passes "privilege tax" – deadline for final action is today

by DLA Piper on

The Illinois Senate has passed SB 1719, which would impose a 20 percent "privilege tax" on fees earned by partnerships and S corporations engaged in the business of conducting "investment management services."...more

Holding Defendants' Knowledge Of Potential Tax Issues Subject To Disclosure Under Item 303, Southern District Of New York Denies...

by Shearman & Sterling LLP on

On May 23, 2017, Judge Victor Marrero of the United States District Court for the Southern District of New York denied in part and granted in part a motion to dismiss a putative securities class action against Inovalon...more

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