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Tax General Business Finance & Banking

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

Cannabis Industry FAQ

by Pepper Hamilton LLP on

Can marijuana businesses receive federal copyright protection? Yes. The requirements for registration with the U.S. Copyright Office are that the work is original, creative and fixed in some form of expression. These...more

Employee Loan Or Compensation?

by Farrell Fritz, P.C. on

Everyone recognizes the importance of debt financing to a business. The business needs liquidity to purchase or improve assets, or to pay expenses. It borrows the necessary funds from an institutional lender that requires...more

Law Enforcement can Follow the Money thanks to the Fifth Pillar of the Final CDD Rule

by Foodman CPAs & Advisors on

Under the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) issued a “Fifth Pillar” of the Final Customer Due Diligence (CDD) Rule on May 2016. The covered financial institutions (Banks; Brokers or...more

ILPA Issues Guidance on “Subscription Lines of Credit and Alignment of Interests”

by Goodwin on

Subscription lines of credit, or capital call facilities – which are just two of the many names given to borrowing arrangements put in place by private fund managers at the fund level – have been in the market for many years...more

Condominium Issue with Long-Term Tax-Exempt Bond Financing

by Ruder Ware on

We recently helped a client complete long-term tax-exempt bond financing of a portion of a mixed-use condominium. These projects raise interesting issues. Long story short, if you find yourself in a similar situation, you...more

AML Due Diligence Standards for U.S. Lawyers

by Ballard Spahr LLP on

Increasingly, international bodies are calling for higher standards for gatekeepers, known in the parlance of the Financial Action Task Force (“FATF”) as “designated non-financial businesses and professions” (“DNFBPs”)....more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Hogan Lovells China Desk Brochure

by Hogan Lovells on

A bridge between China and Europe, the Middle East and Africa - The Hogan Lovells China Desk seeks to help you benefit from the opportunities arising from the evergrowing economic ties between the EMEA region and China....more

Brussels Regulatory Brief: June

by K&L Gates LLP on

On May 15, 2017, the European Commission (“Commission”) announced it had opened a formal investigation into a global pharmaceutical company for possible abuse of dominant position. The alleged conduct of the company,...more

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

Bennett Jones Spring 2017 Economic Outlook

by Bennett Jones LLP on

In our Fall 2016 Economic Outlook, we set out at some length our analysis of the main factors which have contributed to the low “new normal” growth rates the world has experienced since 2011. We argued that trend annual...more

UK Criminal Finances Act 2017: A Dechert "Dirty Money" Trilogy

by Dechert LLP on

Part One: "A Fistful of Tax Dollars" - A New Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion.. The Criminal Finances Act 2017 represents a further significant development in the approach to the...more

IRS Issues New Rules for Management Contracts involving Tax-Exempt Financed Facilities

by Miller Canfield on

The Internal Revenue Service (IRS) issued Revenue Procedure 2017-13 (Rev. Proc. 2017-13) on Jan. 17, 2017. The procedure provides more flexible, modern rules for structuring management contracts involving tax-exempt financed...more

Outline for Discussion of New Issue Price Rules

New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon. This outline describes the new issue price rules, provides a high-level strategic analysis to help guide a...more

Tax Round Up - May 2017

by Proskauer Rose LLP on

Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Il nuovo regime fiscale dei piani di co investimento di amministratori e dipendenti

L'articolo 60 del d.l. n. 50 del 24 aprile 2017, pubblicato in G.U. 24 aprile 2017 (di seguito "Decreto"), disciplina il regime fiscale applicabile ai redditi derivanti dalla partecipazione ad OICR, società o enti percepiti...more

Waiver of contractual right

by Hogan Lovells on

In a binding private ruling published on 2 May 2017, SARS was requested to confirm the income tax, donations tax, capital gains tax and value-added tax consequences of the proposed waiver of a right to receive an annual...more

Nasdaq Report: Reigniting America’s Economic Engine

The Nasdaq recently published a report, titled “The Promise of Market Reform,” which sets out proposed structural changes that are intended to relieve some of the burdens associated with being a public company. The report...more

IRS Expands Management Contract Guidelines for Projects Financed with Tax-Exempt Bonds

by Holland & Knight LLP on

The Internal Revenue Service (IRS) earlier this year released Rev. Proc. 2017-13 (the Guidelines), which contained new safe harbors for qualified management contracts relating to facilities financed with tax-exempt bonds. The...more

Tax Court Rules that Extensions of Variable Prepaid Forward Contracts Do Not Result in Taxable Exchanges

by Proskauer - Tax Talks on

Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not give rise to a taxable exchange to the obligor because a VPFC is solely an...more

The Impact of Tax Reform on Private Equity

If the past 12 months have taught us anything, it’s that the future is hard to predict. One need only look at the ascendancy of Brexit, President Donald Trump, or even the New England Patriots in the second half of the Super...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Mega luxury brand news yesterday, as LVMH announced a series of moves that, combined with $13.1 billion, helped it take over the 70-year-old French fashion house Christian Dior....more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

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

by Dechert LLP on

CSSF Press Release 17/06 Dated 13 February 2017 - The CSSF confirmed that it follows ESMA on its opinion in relation to the requirements for UCITS share classes....more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part II

by Farrell Fritz, P.C. on

Aside from planning for the taxation of U.S.-sourced rental income, the foreigner must plan for the disposition of the USRP pursuant to a sale. The taxation of gain realized by a foreigner on the sale of an interest in...more

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