State and Local Taxation: Headline News and Trends (January 2015)
How the Rise in Undercover Investigations is Changing the Law
State and Local Taxation: Headline News and Trends (CPE/CLE)
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
Planning For The Exit – What’s Your Exit Strategy?
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Hodgson Russ's Tim Noonon on the Groundbreaking New York Residency Tax Case Gaied v. NYS Tax Appeals Tribunal
How to Avoid Corruption Risks in China
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
Polsinelli Podcasts - The Explosion of Tax Credits in 2014
Cross-Border Update on Investing and Doing Business in the United States
Tax Developments Affecting Health Care Organizations and Investor-Owned Hospital Companies
Did the IRS Just Help or Hurt the Bitcoin Economy?
Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
The Australian Government has today introduced the draft Tax and Superannuation Laws Amendment (Employee Share Schemes) Bill 2015 containing measures designed to ease the tax impost for employee shares schemes, to make...more
As discussed in prior posts, an asset sale transfers only the assets of the business, whereas a stock sale transfers some or all of the ownership interest in the business as well as its obligations and liabilities....more
The case of Terrace Hill (Berkeley) Ltd provides a further insight into the distinction between trading and investment.
Originally published in Tax Journal, Page 6 , on March 13, 2015....more
HMRC are expected to consult on revisions to their published guidance to clarify the circumstances in which they will treat loan servicing in securitisation arrangements as exempt for VAT purposes....more
On 3 March 2015, legislation introducing the Exploration Development Incentive (EDI) officially passed the Australian Senate. The legislation is expected to receive Royal Assent in the coming days. The EDI has been introduced...more
On February 27, 2015, an Administrative Law Judge (ALJ) determined that, contrary to claims by the SEC, interests in an LLC that invested in conservation easements as a tax deduction mechanism were not “securities” within the...more
NUMBER OF THE WEEK: $42,268. The projected average taxable income of all tax returns in 2015, according to the Joint Committee on Taxation’s Feb. 27 report on “Fairness and Tax Policy.” The report also projects that the top...more
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.”...more
On Sunday March 1, 2015, the Honourable Joe Oliver, Federal Minister of Finance addressed the Prospectors & Developers Association of Canada (“PDAC”) at the annual PDAC Convention in Toronto and announced certain proposals...more
Following a successful bond issuance, an issuer may consider a “tap” issuance as a way to access further funding.
White & Case offers some “Tips for Taps” for issuers and underwriters in accessing the capital markets...more
The earnings and profits (E&P) of a corporation dictate the income tax treatment of non-liquidating distributions it makes to its shareholders. Distributions from a corporation to the extent of its current or accumulated E&P...more
On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more
Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more
Wednesday, the 5th circuit reversed the Tax Court and held in Pilgrim’s Pride that a taxpayer could receive an ordinary loss on the abandonment of a stock interest....more
The Hong Kong government has announced in its latest budget a planned extension of the existing offshore funds tax exemption to bring offshore private equity funds investing in or through Hong Kong, within its scope. The...more
CSSF Reminder Regarding Nomination of Depositaries of Bearer Shares -
The Luxembourg regulator for the financial services industry (CSSF) has issued a press release and a FAQ in relation to the immobilization of bearer...more
Compensation paid by a publicly-traded corporation to its Chief Executive Officer and three other highest compensated officers (other than the Principal Financial Officer) is generally not tax deductible to the extent the...more
Welcome to the updated edition of DLA Piper’s Guide to Going Global – Global Equity, Stock Options.
GUIDE TO GOING GLOBAL SERIES -
Many companies today aim to scale their businesses globally and into multiple...more
In a number of transactions in the UK mid-market in which we have been involved recently, we have noted a departure from the traditional private equity buy-out model, whereby the sponsor acquires 100% of the target and...more
Welcome to the updated edition of DLA Piper’s Guide to Going Global – Global Equity, Restricted Stock and RSUs.
GUIDE TO GOING GLOBAL SERIES -
Many companies today aim to scale their businesses globally and into...more
Welcome to the updated edition of DLA Piper’s Guide to Going Global – Global Equity, Employment Stock Purchase Rights.
GUIDE TO GOING GLOBAL SERIES -
Many companies today aim to scale their businesses globally...more
It is no secret that when a public company announces a merger, lawsuits follow. There is nothing inherently wrong with this phenomenon. If the merger price is woefully unjustifiable or if shareholders are not given adequate...more
Real estate investment trust (REIT) spin-offs provide a means for companies to unlock the value of their real estate. Due to current economic conditions, more companies in more business sectors are considering separating...more
In the current low interest rate environment, yield-hungry investors have been particularly attracted to real estate investment trusts (REITs), which, as tax-efficient, flow-through investment vehicles, aim to pay regular...more
Investors that own more than 5% of a public company’s securities and file under the exempt category (which includes most venture capital firms and other similar investors) are required to file their beneficial ownership...more
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