Tax General Business Securities

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Supervisory “Concerns” with Shareholder Protection Arrangements

In December 2015 (following years of sporadic and seemingly random criticism) of shareholder protection arrangements, the Board of Governors of the Federal Reserve System issued guidance that the Federal Reserve “may” object...more

Tax Exclusions for Sale of Stock Issued by Qualified Small Business Corporations Becomes Permanent — At Least Temporarily

Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more

Recent development on taxation of securities lending transactions

On 13 January 2016 the German Federal Finance Court (Bundesfinanzhof –“BFH”) published its ruling on securities lending transactions (“Ruling”). The Ruling was long-awaited and rumor had it that it might bring about a...more

Annulment of the European Commission´s decision regarding the former "Spanish tax lease structure" - EU General Court Decision:...

Background - On December 17, 2015 the EU General Court of Justice (EUGC) pronounced on appeals of joined matters T-515/13 Kingdom of Spain vs Commission and T-719/13 Lico Leasing, S.A., E.F.C. and Pequeños y Medianos...more

Annual ISO and ESPP Information and Reporting Requirements

Annual Information Statements and IRS Returns - Requirement to Report - For (1) any exercise of an incentive stock option (ISO) during 2015 or (2) transfer during 2015 of a share previously purchased pursuant to a...more

Section 162(m) Compliance Reminder

2016 Shareholder Approval Reminder - If a publicly-traded corporation’s equity incentive plan or annual bonus plan was last approved by shareholders in 2011, the plan must be submitted to shareholders for re-approval in 2016...more

Your daily dose of financial news The Brief – 1.14.16

So much for 2 days of optimism. Stocks took another dive yesterday, well into correction territory – NYTimes... Care to guess what that meant in Asia today (and Europe, for that matter)? – WSJ... Goldman Sachs is...more

Another ROBS Gone Wrong – IRS Disqualifies ESOP

On November 23, 2015 the U.S. Tax Court issued a declaratory judgment that the Internal Revenue Service (IRS) did not abuse its discretion in issuing a Letter of Revocation of the tax qualified status of the Fleming...more

Capital Gains Tax Exclusion for Certain New Investments in Small Businesses Made Permanent

President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) on December 18, 2015. Among other provisions, the PATH Act provides that the 100 percent exclusion from gross income of...more

Senate Passes Extenders Legislation – Moves to President for Signature

Last week the Senate voted 65-33 to pass the Extenders bill (H.R. 2029) and it moves to the President where it is expected to be signed.  As discussed in more detail in this blog, the legislation makes permanent or creates an...more

100% QSBS Exclusion Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

100% Exclusion for Gains from Qualified Small Business Stock Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

A New Tax System For Managed Investment Trusts

The Tax Laws Amendment (New Tax System for Managed Investment Trusts) Bill 2015 (Bill) was tabled in Parliament on 3 December 2015, along with three supporting bills. If passed in its present form, the Bill will...more

Darden Restaurants and MGM Resorts International Take Different Paths in Unlocking Real Estate Value

In recent years, a number of public companies have sought to unlock the value embedded in their corporate real estate assets by separating the real estate and other assets into two separate entities – a so-called PropCo/OpCo...more

Consider New IRS Guidance on 162(m) When Drafting Proxy Statement Disclosures

Many public companies include a description of Section 162(m) of the Internal Revenue Code in their proxy statements without distinguishing the application of 162(m) between various categories of issuers such as accelerated...more

UK Autumn Statement 2015 – Key Tax Measures

The Chancellor of the Exchequer delivered his budgetary Autumn Statement on 25 November 2015. In this Client and Friends Alert we have outlined the key tax measures that we expect to be of interest to Cadwalader’s clients...more

Your daily dose of financial news The Brief – 11.20.15

The US Treasury Department and IRS are joining forces to address corporate tax inversions with the introduction of new measures aimed at “curtailing companies’ ability to avoid United States tax rates if they move to...more

Be Cautious of Late In the Year Mutual Fund Purchases

This is the time of year to be cautious about buying a mutual fund. Many funds pay dividends near the end of the calendar year in December. If you buy one now, and it pays a dividend, you will be paying taxes for 2015 on the...more

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the "Reports") after a two-year consultation period during which 62 countries and many other stakeholders (such as...more

Where We Stand on Issue Price for Tax-Exempt Bonds

The U.S. Treasury Department and the Internal Revenue Service (IRS) held a public hearing on the definition of issue price for tax-exempt bonds on October 28, 2015. The hearing is another step in the process of changing what...more

The Acquisition and Leveraged Finance Review

During the decade preceding the financial and economic crisis, Austria has developed into a buoyant market for both domestic and international M&A activity, with some of the peak years seeing over 400 deals. Compared to...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Vesting 101 – Whaddya Mean I Don’t Own My Stock?

Vesting is an extremely important concept that arises (or should) among the founders when a company is formed, when equity incentives are granted and when outside investors invest. Although some founders view vesting as yet...more

Employee Benefits Developments - October 2015

The Internal Revenue Service (IRS), consistent with prior regulations from the Department of Health and Human Resources (HHS), issued supplemental proposed regulations requiring employer sponsored health plans to provide...more

US Withholding Tax on Dividend Equivalent Payments Under Swaps

The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on swaps and other financial instruments that are linked to US equities. These...more

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