Tax Securities

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
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U.S. Department of Labor Proposes New Fiduciary Standard

Last week, the U.S. Department of Labor (DOL) issued its highly anticipated, re-proposed regulation addressing when a person providing investment advice with respect to an employee benefit plan or individual retirement...more

The New Section 6501(c)(10) Regulations

The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently finalized Treas. Reg. § 301.6501(c)-1(g), which interprets § 6501(c)(10)’s extended limitations period (and other associated rules) where a...more

Practical Advice for Compliance with Recent Amendments to the Internal Revenue Code Section 162(m) Regulations

The recent amendments to the Section 162(m) regulations largely follow the changes set forth in the proposed regulations issued in 2011, clarifying two exceptions from the Section 162(m) tax deductibility limit...more

IRS Publishes Final Regulations Under Section 162(m)

On March 31, 2015, final regulations of Internal Revenue Code Section 162(m) were published. The final regulations clarify exceptions to the US$1 million annual limit on deductions allowable to publicly held corporations for...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Tax: HMRC Publishes Filing Dates for New AIFM Mechanism for Partnership Deferred Remuneration Arrangements - The Finance Act 2014 introduced a provision intended to help partnerships (including LLPs) that are AIFM...more

IRS Addresses Interaction of Performance Compensation and $1M Compensation Deduction Cap

The IRS recently issued final regulations under Section 162(m), which limits a public company’s deduction of executive compensation in excess of $1M.  The Section 162(m) limits do not apply to performance-based compensation...more

German Fund Taxation: A Roundup of Recent Developments

Germany’s fund taxation regime continues to evolve as the country further refines and reforms domestic tax laws that were subject to significant changes towards the end of 2013 – when Germany introduced new domestic tax rules...more

Fund and Adviser Tax Issues [Video]

Pepper partners Gregory J. Nowak and Steven D. Bortnick presented a webinar for West LegalEdCenter discussing issues that affect private funds and their managers. Over the hour program, Mr. Nowak and Mr. Bortnick covered a...more

IRS Releases Clarifying 162(m) Regulations

The IRS recently released final regulations clarifying two aspects of the “performance-based compensation” exception to the $1,000,000 limit on deductible compensation paid to covered employees under Section 162(m) of the...more

EPCRS Updates: New Guidance Eases Administration of Plan Corrections

The Internal Revenue Service (IRS) has released two Revenue Procedures providing guidance under the Employee Plans Compliance Resolution System (EPCRS) that will facilitate the correction of certain retirement plan defects....more

Executive Compensation Alert: IRS Releases Final Section 162(m) Regulations

Background - Section 162(m) of the Internal Revenue Code (the “Code”) denies a tax deduction to a public company if the compensation paid to its chief executive officer and three other highest compensated officers...more

A Phantom Menace for IPO Companies - US Tax Regulations Restrict the Use of Restricted Stock Units

Section 162(m) of the Internal Revenue Code (“Section 162(m)”) provides for a $1 million dollar limitation on the amount of compensation paid to each of certain named executive officers that public companies may deduct in any...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Luxembourg Fund Sector Continues to Grow - The CSSF press release 15/15 dated 26 March 2015 provides an overview of regulated UCIs at the end of February 2015 and confirms total assets under management of more than EUR...more

Investment in real estate: France-German double tax treaty changes

On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this...more

Tax Alert: AM 2015-01—Does Previously Taxed Income “Tier up” to a Domestic Corporate Shareholder?

In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the...more

Preserving Net Operating Losses (NOL) Carryforward: What Are You Doing to Protect Your Company’s Valuable Tax Assets?

A company’s past NOLs can be used to offset taxable income in future years, subject to certain limitations. For companies that have operated at a significant loss and expect to turn a profit in the foreseeable future, the...more

Locke Lord QuickStudy: IRS Clarifies Performance-Based Compensation Exception Under Code Section 162(m)

On March 31, 2015, the Internal Revenue Service (IRS) published final regulations under Section 162(m) of the Internal Revenue Code (the Code). Code Section 162(m) disallows a deduction by any publicly-held corporation for...more

Easier, Less Costly Alternatives for Correcting Retirement Plan Mistakes

In two recent Revenue Procedures, the Internal Revenue Service (IRS) has modified the Employee Plans Compliance Resolution System (EPCRS), the IRS correction program for retirement plans. Revenue Procedure. 2015-27 reduces...more

Ensure Compliance with Final Regulations on Equity Awards

The Department of the Treasury has issued final regulations setting forth changes to the current regulations under Internal Revenue Code (Code) Section 162(m). Code Section 162(m) precludes a deduction by a public corporation...more

IRS Releases Amended Section 162(m) Regulations Clarifying How to Preserve the Deductibility of Certain Compensation for Public...

The Internal Revenue Service recently amended the regulations under Internal Revenue Code Section 162(m). Section 162(m) applies to publicly held companies and generally limits the tax deduction that a public company is...more

Developments in the Luxembourg Financial Sector

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind...more

Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation

Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more

Final IRS Regulations Under Section 162(m) Will Impact Transition Rule Applicable to Newly Public Companies

On March 31, 2015, the IRS issued final regulations under Section 162(m), the tax code provision which limits the deduction for compensation paid to certain public company executive officers. As signaled by the proposed...more

IRS Releases Final Regulations Clarifying 162(m) Limitation on Compensation

Section 162(m) of the Internal Revenue Code precludes the deduction by public companies for compensation paid to certain covered employees in excess of $1,000,000 in any taxable year. This limitation on deduction does not...more

New York Budget Incorporates More Significant Tax Changes

New York Governor Andrew Cuomo introduced his 2015-2016 budget and accompanying legislation on January 19, 2015 (the proposed legislation). After much negotiation, the Legislature just enacted the Budget Bill (the "2015...more

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