Tax Mergers & Acquisitions

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

OECD BEPS Working Groups issue three discussion drafts

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released three documents: its proposed updated guidelines on the application of the transactional profit split, draft...more

"IRS Offers Limited Safe Harbors for Recapitalizations Before Spin-Offs"

On July 15, 2016, the Internal Revenue Service (IRS) released a new revenue procedure, Rev. Proc. 2016-40, providing safe harbors for transactions in which a corporation (Distributing) obtains the requisite control of a...more

Tax Court Allows Deduction for Advisory Fees in M&A Transaction

The Tax Court of Canada has recognized in a recent case that “oversight expenses” – notably investment banking and other professional advisory fees for services rendered to boards of directors in their discharge of oversight...more

Treasury and IRS Issue New Spin-Off Proposed Treasury Regulations On Device and Active Trade or Business Requirements

On July 14, 2016, the Treasury Department and the IRS issued proposed regulations under Section 355 on spin-off transactions (the “Proposed Regulations”) that provide guidance with respect to the spin-off device prohibition...more

Safe Harbor Acquisition of Control for Spin-Offs

Code Section 355, and related Code provisions, when applicable, will allow a corporation to spin-off or split-off a subsidiary corporation to its shareholders without triggering gain to the corporation or its stockholders....more

Proposed Regulations Would Block Some Spinoffs

Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness...more

A Blueprint for Maintaining an Individually Designed Qualified Plan after the IRS’s Determination Letter Program Cutback

In Depth - On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37. Effective January 1, 2017,...more

Proposed Section 409A Regulations Facilitate Common Pay Practices

The Internal Revenue Service (IRS) has proposed a number of updates to current regulations governing nonqualified deferred compensation under Section 409A of the Internal Revenue Code of 1986, as amended. The proposed updates...more

Revised listings due diligence guidelines issued by the Association of Banks in Singapore

The Association of Banks in Singapore (ABS) introduced its revised due diligence guidelines (Enhanced Guidelines) in respect of listings on the Singapore Exchange Securities Trading Limited (SGX-ST) on 13 May 2016. These...more

Brexit Update: What’s Next for the Global Marketplace

In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...more

Renewable Energy Update - July 2016

Renewable Energy Focus - Senator Heinrich to introduce energy storage tax credit bill - Greentech Media - Jul 5 - There will soon be an energy storage tax credit proposal in both the House and Senate. Senator...more

Global Private Equity Newsletter - Summer 2016 Edition: LBO & Management Packages In France: Are Recent Developments In The...

The management packages offered to managers in LBOs can sometimes be differentiating factors for financial sponsors enabling them to win a competitive process for the acquisition of a target company. However, although...more

"Proposed Treasury Regulations Revolutionize Tax Rules Governing Intercompany Financing Transactions"

Recently proposed Treasury regulations, which will likely be finalized this year, promise to alter the tax treatment of a wide range of intercompany financing transactions dramatically, upending nearly a century of law...more

Energy Transfer May Terminate Merger Agreement Based on Lack of Tax Opinion

In a litigation involving one of the biggest M&A deals in 2015, the Delaware Court of Chancery ruled that it will not compel Energy Transfer Equity, L.P. to complete its proposed acquisition of The Williams Companies, Inc. It...more

Brexit: Tax Implications

The majority has spoken: on Friday 24 June, it was announced that the UK had voted to leave the European Union (the “EU”). The full implications of this decision are largely unknown, given that the UK is navigating...more

Deductibility of Transaction Costs for a Target Company: No Safe Harbor in Deemed Asset Deals

On June 10, 2016, the Internal Revenue Service released a Chief Counsel Memorandum dated July 8, 2015, addressing the issue of whether a target S-corporation, which participated in a transaction in which the parties made a...more

Taking the LLC or Partnership Public [Video]

In this short video, Pepper partner Howard Goldberg discusses a tax-advantaged structure for taking an LLC or partnership public, the "Up-C" structure. ...more

A Guide to Doing Business in Italy

Italy is renowned for its rich art, cuisine, history, fashion, and culture; its beautiful coastline and beaches; its mountains; and priceless ancient monuments. In fact, Italy is a top tourist destination and has more World...more

"IRS Expands REIT Spin-Off Restrictions, Extends REIT Built-in Gains Period to 10 Years"

On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all merger-and-acquisition activity by C corporations and real estate investment...more

Private equity in Italy: market and regulatory overview

How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more

The Mergers and Acquisitions Incentive Scheme for Singapore companies

The mergers and acquisitions (M&A) allowance and stamp duty relief schemes together form the M&A Scheme. This scheme was first introduced in Budget 2010 to encourage companies in Singapore to grow their businesses through...more

Saving Time and Money when Selling a Small Business

Advance planning is crucial when you decide to sell your small business. You need to be at the center of that planning. Don’t abdicate your responsibility for selling your business to your lawyer, your accountant or your...more

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

The Rosenbaum Law Firm Review - May 2016

The New Fiduciary Rule: What It Means To Plan Sponsors - Bottom line: what does it mean? If you're a retirement plan sponsor and, unless you've been living under a rock, you've probably heard about the Department...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

331 Results
|
View per page
Page: of 14

Follow Tax Updates on:

JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×