Tax Business Organization Securities

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Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions – With Retroactive Effect!

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the circumstances under which related corporations (and, in some cases,...more

Pennsylvania Audits Public Companies for Unclaimed Securities

Holders that use third-party transfer agents, such as Computershare, should check their mailboxes, as they are likely to have a notice from Pennsylvania of an unclaimed property audit. Pennsylvania has engaged...more

French 3% contribution tax on distributions: Claim opportunities for French subsidiaries of MNEs following new developments...

On April 6, 2016 the First Instance Court of Montreuil filed a request with the French Constitutional Court in relation to potential breaches of the French Constitution (more precisely the Declaration of Human Rights dated...more

Partnerships Must Respond to New Audit Rules

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

IRS Rules Could Treat Related Party Debt as Stock

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

Program Related Investments: Final Regulations

Final Regulations Highlight the Broad Range of Available PRI Purposes, Recipients and Financial Structures - Final program related investment (PRI) regulations released and effective on April 25, 2016 illustrate the...more

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

MIDCO Transactions and the Expanding Universe of Transferee Liability

On April 20, 2016, partner Lawrence Hill (New York-Tax) presented a paper (co-authored with counsel Richard Nessler (New York-Tax)) titled “MIDCO Transactions and the Expanding Universe of Transferee Liability” to The Tax...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

IRS and Treasury Issue Proposed Regulations on Deemed Stock Distributions

Executive Summary - On April 12, 2016, the Internal Revenue Service (“IRS”) and Treasury Department issued long-awaited proposed regulations (REG-133673-15, RIN 1545-BN07) (the “Proposed Regulations”) regarding the...more

The Pepper Minute: Buying and Selling the S Corporation [Video]

There are significant tax aspects involved in buying and selling an S corporation. In this short video, Pepper partner Howard Goldberg takes a few minutes to discuss various forms of buying and selling an S corporation’s...more

US Internal Revenue Service and US Treasury Department Issue Anti-Inversion Regulations

The US Internal Revenue Service issued a proposal under Section 385 of the Internal Revenue Code with respect to the treatment of instruments issued by corporations in related-party transactions as debt or equity for federal...more

Collective Investment Trusts as Retirement Plan Investment Options: Important Tax and ERISA Considerations [Video]

Nexsen Pruet tax and employee benefits attorney Sue Odom says retirement plan fees and expenses have been the “hot topic” for the past several years. We’ve seen increased regulation through disclosure requirements and...more

Sweeping Changes Proposed to Tax Treatment of Related-Party Debt May Impact Private Funds

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would potentially treat related-party debt, in whole or in part, as equity for U.S. tax purposes. The Proposed Regulations generally apply to...more

Treasury and IRS Issue Regulations on Inversions and Earnings Stripping

On April 4, 2016, the Treasury Department and the IRS issued temporary regulations under Section 7874 on inversion transactions that added some new restrictions and implemented provisions previewed in two prior IRS notices...more

Preserving Your Family Business (or Sale Proceeds) for Generations

As promised, below is a follow-up to my February 29th post. There, I discussed estate tax planning. Below, I want to introduce generation skipping tax planning, using some similar tools. As of 2016, each person has a...more

The Hidden Tax Trap in Your Family Business—and How to Avoid It.

You have a business. You have a family. You have a family business. And frequently, the family makes decisions about the business. Sometimes, those decisions are not formalized....more

Question and Answer from the Tax Equity Structuring, Financial Modeling and HLBV Accounting Seminar

The tax equity investor invests to own only a portion of the production tax credits (PTCs) up front, since there is an unknown of the actual production levels of the wind farm. What does the project company do with the...more

In Case You Missed It: Launch Links - March 2016 #3

Some interesting links we found across the web this week: The SEC could change the requirements for investing in startups, and that’s not good - With its new equity crowdfunding rules soon to take effect, the...more

Incorporating a Partnership to Take Advantage of the Qualified Small Business Stock Rules (Update)

This is an update to a 2013 Legal Alert by Bahar Schippel and Bill Kastin titled: Excluding 100% of Gain From the Sale of Qualified Small Business Stock Acquired in 2013. Among the tax breaks included under the...more

2016 IPO Report

Our 2016 IPO Report offers a detailed analysis of, and outlook for, the IPO market, plus useful IPO market metrics. We look at rates of adoption of JOBS Act relief by emerging growth companies, and recent FAST Act amendments...more

Federal Budget 2016 Extends Mineral Exploration Tax Credit

Canada’s Liberal party released their first Federal Budget on March 22, 2016 since taking office last year. Despite projecting a staggering deficit of approximately $30 billion, the Budget contains welcome news to issuers of...more

UK Budget 2016: Tax implications for the private equity sector

The private equity sector was a net loser from last week’s Budget, with the proposed restrictions on interest deductibility and a lifetime limit on employee shareholder schemes. The extension of entrepreneurs’ relief is...more

Registration tax on pledges of SRL quotas

The registration tax on pledges of Srl stocks granted to guarantee the obligations of third parties, does not find uniform application between the different Offices of the Italian Revenue Agency....more

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