Tax Finance & Banking Securities

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
News & Analysis as of

Doing Business in Latin America and The Caribbean: Columbia

Colombia is located in the northernmost part of South America. Its population is estimated at over 45 million people, with at least 10 million living in the capital city of Bogotá. Colombia’s main language is...more

Doing Business in Latin America and The Caribbean: Cayman Islands

The Cayman Islands are located in the western Caribbean Sea about 480 miles south of Miami and 180 miles northwest of Jamaica. Of the three islands, Grand Cayman is the largest with an area of 76 square miles. The islands of...more

The Housing Finance Reform and Taxpayer Protection Act of 2014

This article provides a brief summary of the key provisions of a new bi-partisan Senate bill, based on the Housing Finance Reform and Taxpayer Protection Act of 2013, as well as a brief discussion of a new House of...more

Did the IRS Just Help or Hurt the Bitcoin Economy?  [Video]

Apr. 1, 2014 -- Houman Shadab, Associate Professor at New York Law School, talks with Lee Pacchia about recent developments in the bitcoin economy....more

Corporate & Tax E-Note - March 27, 2014

In This Issue: - High Court Considers Whether Corporations Can Lie to Investors - Nasdaq Enters Pre-IPO Market with Private Exchange - Many Early-Stage Start-Ups Still Struggle to Get Funding - Venture...more

IRS PFIC Regs

The IRS issued definitions and reporting requirements for shareholders of passive foreign investment companies (PFICs) effective December 31, 2013 for US tax returns for 2013 and onwards. The regulations provide guidance for...more

IRS Issues Final Regulations on Property Transferred for Services Under Section 83

The Treasury Department (Treasury) and Internal Revenue Service (IRS) have issued final regulations clarifying the forfeiture provisions under Section 83 of the Internal Revenue Code of 1986, as amended, for transactions...more

Netherlands: tax treatment of hybrid finance instruments in the wake of two landmark cases

The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance instruments. The question in both cases was whether shares can be requalified as a debt instrument for...more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

In Case You Missed It - Interesting Items for Corporate Counsel (Cumulative) - March 13, 2014

The U.S. Supreme Court recently ruled in Lawson v. FMR LLC that the whistleblower provisions of the Sarbanes-Oxley Act protect employees who work for contractors and subcontractors of public companies and not just employees...more

Tax Reform Proposal Takes Aim at Executive Compensation

On February 26, 2014, U.S. Congressman Dave Camp released a comprehensive tax reform proposal that includes several provisions intended to limit or restrict executive compensation. Congressman Camp’s proposal includes the...more

Tax Court Rules Amounts Paid Out Of Ponzi Scheme Not Taxable

The tax treatment of amounts paid out of failed Ponzi schemes is once again in the news. In Roszko v. The Queen (2014 TCC 59), the Tax Court of Canada allowed the taxpayer’s appeal and held that amounts paid out of a...more

Tax Court Rules on Built-In Gains Discount and Appraiser Qualification

On February 11, 2014, the United States Tax Court issued a memorandum opinion (i) determining the proper method for valuing a holding company (i.e., an S or C corporation holding marketable securities or appreciated...more

The Camp US tax reform proposal: what’s inside?

House Ways and Means Committee Chairman Dave Camp (R-Michigan) this week introduced a draft of the most comprehensive reform of the Internal Revenue Code in decades. The key principles in the draft are: (1) a...more

Legislative Report – MLP Parity Act

What: The MLP Parity Act (the “Act”) is a bill currently before the U.S. Senate Committee on Finance seeking to expand Section 7704(d) of the Internal Revenue Code (which defines “qualifying income” for publicly traded...more

Spain’s Basque Country extends participation exemption regime to capital gains on transfer of shares in Spanish companies

Spain’s autonomous Basque Country region has extended its participation exemption regime (applicable to foreign participations) to capital gains derived from the transfer of shares in Spanish companies (dividends were already...more

Corporate and Financial Weekly Digest - Volume IX, Issue 8

In this issue: - OTC Markets Proposes Amendments to OTCQX Rules and New Rules for US Banks - SEC Approves Changes to FINRA BrokerCheck Disclosure Rule 8312 - SEC to Examine Never-Before Examined...more

Insurance Topics We Will Be Watching in 2014

With the first month of the year behind us, this report outlines major insurance topics that we will be watching throughout 2014. Forces, trends and events that we believe will affect regulation, transactions and...more

Successful Strategies For Doing Business In Asia: India

1. What role does the government of India play in approving and regulating foreign direct investment? Historically, India has been a regulated economy since its independence. The government of India (GOI) launched a...more

Pubblicato In G.U. Il Decreto Legge Sulla Voluntary Disclosure Per Il Rientro Dei Capitali All'estero

Il decreto legge 28 gennaio 2014, n. 4 (pubblicato in G.U. n. 23 del 29 gennaio 2014 – di seguito "Decreto") introduce nel d.l. 167/1990 (in materia di "Rilevazione ai fini fiscali di taluni trasferimenti da e per l'estero di...more

"Government Enforcement: Aggressive Efforts Continue Around the Globe"

Government enforcement efforts in 2013 produced major settlements of matters relating to the global financial crisis, high-profile insider trading convictions, near-record amounts of FCPA settlements, and new pledges of...more

New Temporary Regulations Expand Reach of U.S. Anti-Inversion Rules and Permit De Minimis Continuing Ownership in Foreign Acquirer

On January 16, 2014, temporary regulations were issued by the U.S. Department of the Treasury and the Internal Revenue Service (IRS) with respect to corporate inversions under Section 7874 (the "New Regulations"), which...more

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) are required to review their compliance policies and procedures at least...more

Private Funds In Focus - Winter 2014

Year End Update – Compliance: Certain Upcoming U.S. Regulatory Deadlines - The list below briefly summarizes various regulatory obligations and filing deadlines for private fund managers under U.S. rules....more

310 Results
|
View per page
Page: of 13

Follow Tax Updates on: