Tax Law, Finance & Banking, Commercial Law & Contracts

Legal Alert: Supreme Court Unanimously Rules in Favor of Taxpayer, Holds U.K. Windfall Tax Creditable

by Sutherland Asbill & Brennan LLP on 5/23/2013

The United States Supreme Court held Monday in PPL Corporation v. Commissioner (No. 12-43) that a U.S. taxpayer was entitled to claim a foreign tax credit on its share of a “windfall tax” imposed on the taxpayer’s United...more

Financeable Ground Leases – They’re Not Just for Development Sites Anymore

by Marc Intriligator | Cozen O'Connor on 5/23/2013

In years past, ground leases were used primarily as vehicles for the development or redevelopment of “stand alone” real estate. The fee owner – typically an investment group that purchased an income property years ago and now...more

Legal Alert: Tax Court Finds Indirect Prohibited Transaction in IRA

by Adam Cohen, Mikka Gee Conway, Jonathan Goldman, Carol McClarnon, Alice Murtos, Joanna Myers, Vanessa Scott, W. Mark Smith, Rich Sun, William Walderman, Carol Weiser | Sutherland Asbill & Brennan LLP on 5/22/2013

In Peek v. Commissioner (May 9, 2013), the U.S. Tax Court ruled that two taxpayers had engaged in an indirect “prohibited transaction” with their individual retirement accounts (IRAs) when they provided personal guarantees...more

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 5/22/2013

In a Written Ministerial Statement made in UK Parliament on 21 May 2013, Treasury Economic Secretary Sajid Javid MP announced the Treasury’s intention to make a crucial and very welcome clarification to the recent HMRC Brief...more

Big Incentives for Investments in Cybersecurity

by Javier Siervo | Berkeley Research Group, LLC on 5/17/2013

Recently, Maryland Governor Martin O’Malley signed into law the Cybersecurity Investment Incentive Tax Credit. The credit is to be used against the state income tax of a Maryland cybersecurity company. To be eligible for the...more

Insights - Spring 2013: Developing Federal Common Law of Successor Liability

by Regina Joseph | Shumaker, Loop & Kendrick, LLP on 5/17/2013

When a purchaser acquires substantially all the assets of a seller, the purchase agreement typically provides that the purchaser does not assume seller’s liabilities except to the limited extent specifically set forth...more

IRS Issues Final Regulations Treating Qualified Stock Dispositions as Asset Sales

by Wilson Sonsini Goodrich & Rosati on 5/16/2013

On May 10, 2013, the Internal Revenue Service (IRS) and Treasury Department released the long-awaited final regulations under Section 336(e) of the Internal Revenue Code, treating certain sales, exchanges, and distributions...more

Tax-Efficient Capital Vehicles for Unregulated Utilities: REITs, MLPs and Up-Cs Considered

by Nickolas Gianou, David Levy, Sean Shimamoto | Skadden, Arps, Slate, Meagher & Flom LLP on 5/15/2013

Over the last several years, a confluence of political and market developments have made capital for renewable energy projects harder to come by, which has affected the ability of unregulated affiliates of public utilities...more

Budget 2013-14: The Government targets multinationals to recover from the GFC - Baker & McKenzie

by Dixon Hearder, Amrit MacIntyre, John Walker | Baker & McKenzie Australia on 5/15/2013

The Treasurer has delivered the 2013-14 Budget. With the Treasurer noting that almost $170 billion has been wiped off tax receipts since the GFC, a series of measures increasing the tax burden of multinationals, foreign...more

Oregon Tax Credit Opportunities

by Michael Batelli | Berkeley Research Group, LLC on 5/15/2013

The Oregon Department of Revenue, in conjunction with the Oregon Film and Video Office, will auction 12,000 income tax credit certificates, worth $500 each, for a total of $6 million....more

At Last: Final Regulations Issued Under Section 336(e)

by Dennis Allen, Robert S. Chase II, Reginald Clark, Jeffrey Mace, Daniel McKeithen, Michael Miles, William Pauls, David Roby, Jr., Christopher Schoen, William Sheumaker, Carol Tello, more +H. Karl Zeswitz, Jr. | Sutherland Asbill & Brennan LLP on 5/14/2013

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more

2013 Maryland IDOT Legislation Expands Exemption Amount Applied For Recordation Tax

by John Wetzel | Niles, Barton & Wilmer, LLP on 5/14/2013

As a result of recent Maryland legislation, commercial property owners currently considering the financing or refinancing of their real estate may achieve significant recordation tax savings when using so-called “indemnity...more

Tales from the Crypt -- Post-Mortem Planning Using Private Placement Insurance Products

by Gerald Nowotny on 5/9/2013

Overview - This article discusses the use of private placement products - private placement deferred variable annuities (PPVA) and private placement life insurance (PPLI)- in post mortem income tax and transfer tax...more

Mortgagees: Don’t Lose Collateral — Take Action To Ensure You Receive Notice Of Pending Tax Deed Sales

by Christopher Linde | Burr & Forman on 5/9/2013

Summary: Mortgagees and other lienholders whose proper address does not appear in a recorded mortgage or lien may not receive notice of a pending tax deed sale and may therefore lose collateral. A recent Florida court held...more

UAE Launches New Financial Free Zone in Abu Dhabi

by Natalie Boyd, Amr Jaghoub, Simon Mabin | K&L Gates LLP on 5/9/2013

The federal government of the United Arab Emirates (“UAE”) has issued legislation establishing a new financial free zone in Abu Dhabi. The name of the new free zone, “Global Marketplace Abu Dhabi” (“GMAD”), serves as a...more

CFPB Finalizes Revisions to Remittances Rule, Sets October 28 Effective Date

by Alan S. Kaplinsky, Jeremy T. Rosenblum, Mercedes Kelley Tunstall | Ballard Spahr LLP on 5/8/2013

The Consumer Financial Protection Bureau has finalized revisions to its remittance transfers rule and set October 28, 2013, as the rule’s new effective date. While not entirely eliminating the requirement for remittance...more

New Directive Correctly Resolves Use Of Transaction Cost Safe Harbor For Milestone Payments – Questions Nonetheless Linger

by Ellen McElroy | Pepper Hamilton LLP on 5/8/2013

A new directive specifies that Large Business & International (LB&I) examiners should not challenge a taxpayer’s treatment of eligible milestone payments when success-based fees are incurred, provided a safe harbor election...more

Home

Legal News

Find a Lawyer

Browse Subjects

Subscribe

Pro Services

For Reporters

Tax Law › Finance & Banking › Commercial Law & Contracts

Legal Alert: Supreme Court Unanimously Rules in Favor of Taxpayer, Holds U.K. Windfall Tax Creditable

Financeable Ground Leases – They’re Not Just for Development Sites Anymore

Legal Alert: Tax Court Finds Indirect Prohibited Transaction in IRA

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

Big Incentives for Investments in Cybersecurity

Insights - Spring 2013: Developing Federal Common Law of Successor Liability

IRS Issues Final Regulations Treating Qualified Stock Dispositions as Asset Sales

Tax-Efficient Capital Vehicles for Unregulated Utilities: REITs, MLPs and Up-Cs Considered

Budget 2013-14: The Government targets multinationals to recover from the GFC - Baker & McKenzie

Oregon Tax Credit Opportunities

At Last: Final Regulations Issued Under Section 336(e)

2013 Maryland IDOT Legislation Expands Exemption Amount Applied For Recordation Tax

Tales from the Crypt -- Post-Mortem Planning Using Private Placement Insurance Products

Mortgagees: Don’t Lose Collateral — Take Action To Ensure You Receive Notice Of Pending Tax Deed Sales

UAE Launches New Financial Free Zone in Abu Dhabi

CFPB Finalizes Revisions to Remittances Rule, Sets October 28 Effective Date

New Directive Correctly Resolves Use Of Transaction Cost Safe Harbor For Milestone Payments – Questions Nonetheless Linger

New Maryland Law Provides Indemnity Deeds of Trust (IDOT) Relief

Integrating Foreign Currency Hedges With Respect To Stock Purchase And Sale Agreements

Maryland Again Changes Recordation Tax Payable on Indemnity Deeds of Trust - Effective as of July 1, 2013

BVI, Cayman in discussions with UK government

Guide To Deducting Meals And Entertainment Expenses

Sales Of Condominium Units Under Audit By Canada Revenue Agency

Louisiana Receivers in Foreclosure: Application of Payments to Costs and Expenses

Tax Talk -- Volume 6, No. 1 -- April 2013

Expand Your Reach