Tax Law, Finance & Banking, Securities Law

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

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

Financial Services Legislative and Regulatory Update -- May 13‚ 2013

by Abby Matousek, Jason M. Rosenstock | Mintz Levin - Public Finance on 5/13/2013

In This Issue: Leading the Past Week; Legislative Branch; Executive Branch; and Upcoming Hearings. Excerpt from Leading the Past Week - What had been a relatively quiet week, where until Friday it seemed...more

Verbatim: Global Compliance - Quarterly Newsletter: Spring 2013

by Orrick, Herrington & Sutcliffe LLP on 5/10/2013

We've highlighted a few notable developments in corporate governance law taking place this spring that may be of interest to you. For more information on any of the topics listed below, please contact us at...more

A Compilation of Enforcement and Non-Enforcement Actions - May 01, 2013

by Michael G. Dana, Peter D. Fetzer, Terry D. Nelson | Foley & Lardner LLP on 5/1/2013

* Non-Enforcement Matters: - Legislation Reintroduced to Charge Investment Advisor User Fees - SEC Examination Program for Newly Registered Investment Advisers Reveals Common Areas of Concern - Recent...more

No Happy Trails For Victorville Tax Increment Bond Financing

by Keith Paul Bishop | Allen Matkins Leck Gamble Mallory & Natsis... on 4/30/2013

For more than thirty years, I’ve driven by, but never stopped at, the Roy Rogers and Dale Evans Museum in Victorville, California. The museum eventually relocated to Missouri but reportedly did not survive for long. Despite...more

Options Industry Opposes Market-To-Market Tax Proposal

by Felix Shipkevich | Shipkevich PLLC on 4/26/2013

The options industry is attempting to stop a proposal that would tax most financial derivatives on a market-to-market basis, that values positions based on their fair value....more

What Every Private Equity Fund Manager Should Know About ERISA

by The R. Bernard Law Group on 4/26/2013

What is ERISA? The Employee Retirement Income Security Act of 1974 (“ERISA”) protects the interests of employee benefit plan participants by establishing strict standards of conduct for “plan fiduciaries” – i.e.,...more

When to Reduce “Basis” in S Corporation Stock for a Suspended Loss?

by Darren Mills | Berkeley Research Group, LLC on 4/22/2013

“Basis” is tax lingo for the amount you paid for that security, including, for example, the commission and other fees incurred to acquire it. In practice, basis is generally what the cost of a particular item is for...more

A Cautionary Tale Under Code § 409A: Case Evidences IRS' Willingness To Seek 409A Penalties For Discount Options

by Janet Lowder | Womble Carlyle Sandridge & Rice, PLLC on 4/22/2013

The United States Court of Federal Claims recently issued an opinion confirming that § 409A of the Internal Revenue Code of 1986 applies in the context of discount stock options. The case, Sutardja v. United States, is one of...more

Wall Street Sales Tax Reintroduced on Capitol Hill: Likely a Significant Impact on Private Investment Funds

by David Sussman | Duane Morris LLP on 4/19/2013

On April 17, 2013, U.S. Rep. Keith Ellison (D-Minn.) reintroduced the Inclusive Prosperity Act of 2013 (H.R. 1579) (the "Bill"), a financial transaction tax that, according to its supporters, would provide the federal...more

D.Lgs. 231/2001 - Aggiornamento Normativo E Giurisprudenziale

by Alessandro De Nicola, Ivan Rotunno | Orrick, Herrington & Sutcliffe LLP on 4/19/2013

Si riporta di seguito una breve rassegna dei provvedimenti maggiormente significativi in materia di responsabilità amministrativa degli enti ex D.Lsg. 231/2001. ENTI STRANIERI - TRIBUNALE DI MILANO – Sent. n....more

Important Tax, Securities and Formation issues associated with LLCs, S Corps and C Corps

by The R. Bernard Law Group on 4/18/2013

One of the first hurdles an entrepreneur has to clear when starting a business is which entity type to choose when registering her business. There are many forms to choose from with different tax implications and different...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

by Joshua Kaplan, Jeffrey L. Rubinger | Bilzin Sumberg Baena Price & Axelrod LLP on 4/16/2013

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

Exemptive Relief filed for New “Exchange-Traded Managed Fund”

by Ropes & Gray LLP on 4/15/2013

On March 27, 2013, Eaton Vance applied to the SEC for exemptive relief for a new type of exchange-traded fund, which it calls an exchange-traded managed fund (“ETMF”). Exchange-traded funds (“ETFs”), particularly actively...more

2013 Mutual Funds and Investment Management Conference

by Ropes & Gray LLP on 4/10/2013

In this presentation: - General Counsel’s Address - Keynote Address - General Session — It’s a Small World After All: How Non-U.S. Regulators Affect Your Business - General Session — Closer to...more

EU Transaction Tax Would Hurt Economies, Says ICAP

by Felix Shipkevich | Shipkevich PLLC on 4/8/2013

A proposed financial EU transaction tax would damage the region’s economies, says ICAP, one of the world’s largest inter-bank brokers....more

Corporate & Tax E-Note - March 28, 2013

by Edward Brown, Benjamin Coulter, Kevin Doherty, C. Logan Hinkle, Mignon Lunsford, Debra Lee Mackey | Burr & Forman on 4/3/2013

In This Issue: - SEC Yet to Release Jumpstart Our Business Startups Act Guidelines - IRS Crackdown on Contract Workers Has Small Businesses Concerned - Accelerated Filers Found to be Filing More Restatements -...more

Orrick's Financial Industry Week In Review - April 2, 2013

by Orrick, Herrington & Sutcliffe LLP on 4/2/2013

In This Issue: *Financial Industry Developments - CFTC No-Action Relief for Commodity Trader Advisor Registration - CFTC Regulations on Associated Persons of Swap Dealers and Major Swap Participants -...more

A Compilation of Enforcement and Non-Enforcement Actions - March 29, 2013

by Michael G. Dana, Peter D. Fetzer, Terry D. Nelson | Foley & Lardner LLP on 3/29/2013

Non-Enforcement Matters: - Recent Newsworthy Remarks by the SEC - SEC Issues “Alert” on the Custody Rule - Securities Exchange Act Issues for Exchange-Traded Funds - Mutual Funds’ After-Tax Returns...more

As Clear as Mud! The Investment Diversification Rules for Private Placement Insurance Products

by Gerald Nowotny on 3/25/2013

A. Overview - The investment diversification rules are a critical element in planning for private placement insurance products. One of the underlying marketing premises for the attractiveness of private placement...more

Federal Budget, Economic Action Plan 2013

by Colleen Cebuliak | Dentons on 3/25/2013

On March 21, 2013, the Minister of Finance tabled the 2013 federal budget, Economic Action Plan 2013. There are announced changes which will be of particular interest to the mining sector....more

For Private Equity Investors, Section 1202 May Be Worth Another Look

by Kevin Feeley, Jeffrey Wagner, Thomas Ward, Daniel Zucker | McDermott Will & Emery on 3/22/2013

Included in the American Taxpayer Relief Act of 2012 (ATRA) are provisions that extended some of the more significant benefits of Internal Revenue Code Section 1202, the Code provision that permits eligible noncorporate...more

Tax Measures in 2013 UK Budget

by E.S. Kate Habershon, Katerina Heal | Morgan Lewis on 3/22/2013

UK government supports businesses, focusing on the UK's competitiveness while clamping down on tax avoidance and evasion. On 20 March, UK Chancellor of the Exchequer George Osborne released the UK's 2013 budget. The...more

Recent ECJ VAT Decisions on Investment Management

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 3/19/2013

Two recent decisions of the European Court of Justice (“ECJ”) on the VAT treatment of investment management services illustrate that this is still an area of some uncertainty that is continuing to evolve. The first decision,...more

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Tax Law › Finance & Banking › Securities Law