Tax Securities

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

Cancellation of CFC Loans to US Shareholders – Should the Service Get a Second Bite at the Apple?

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more

IRS Issues New Management Contract Safe Harbors

Almost 20 years ago, the IRS released Rev. Proc. 97-13, outlining multiple safe harbors under which a management contract would not result in private business use of bond-financed proceeds. These safe harbors, while helpful,...more

Management Contracts & Private Business Use–IRS Releases Favorable Guidance

Coming as welcome news to those involved in the municipal bond market, Revenue Procedure 2016-44 provides helpful guidance for governmental issuers and 501(c)(3) borrowers entering into long-term contracts with private...more

Important news for family-held businesses: IRS proposes imminent changes in family valuation discounts

On August 2, 2016, the Treasury Department issued Proposed Regulations to Section 2704 of the Internal Revenue Code. These proposed regulations are directed at family controlled entities (many of which hold operating...more

Treasury Department Issues Proposed Regulations on Valuation Discounts

On Aug. 2, 2016, the Treasury Department issued proposed regulations on valuation discounts. These proposed regulations make sweeping changes to the valuation rules for family-owned entities. If the proposed regulations...more

Focus on Tax Strategies & Developments - August 2016

Brexit: The Consequences for International Tax Planning - Just over a month has now passed since the referendum in which the United Kingdom voted narrowly to leave the European Union: an event which some have...more

IRS Simplifies Section 83(b) Election Process

Under Section 83(b) of the Internal Revenue Code ("Section 83(b)"), a taxpayer who receives certain property subject to vesting as compensation for services (for example, a restricted stock award granted by the taxpayer's...more

IRS Makes Filing an 83(b) Election Easier

On July 25, 2016, the IRS finalized regulations under Section 83 of the tax code that removes a procedural step in the process of filing an 83(b) election....more

Update on the Apparent Demise of the Determination Letter Program

As we previously reported, the IRS had said last year that determination letter program for retirement plans would largely be going away. Rev. Proc. 2016-37 includes information with respect to the future of the determination...more

IRS Eliminates Requirement to Submit Copy of Section 83(b) Elections with Tax Return

The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted...more

Puerto Rico's Act 20 and Act 22 – key tax benefits

In the midst of a complicated fiscal situation, Puerto Rico continues to attract investors and companies through two extant tax incentive packages: Puerto Rico’s Act 20 – the Promotion of Export Services Act –  and Act 22 –...more

Proposed Treasury Regulations Provide Additional Flexibility, Clarity and Planning Opportunities to Sponsors of Deferred...

The IRS recently issued proposed regulations under Internal Revenue Code Section 457 that address, among other things, the interplay between Code Section 457(f) and Code Section 409A. Additionally, the IRS issued clarifying...more

New Rules on Section 83(b) Elections

Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to: - File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more

Executrix Held Liable Under Federal Claims Statute For Actions Taken Prior to Appointment as Executrix

A decedent died while owing over $340,000 in unpaid federal income tax liabilities. His estate was insolvent. The assets of his estate consisted almost entirely of a 100% interest in one corporation and 50% of another...more

IRS Announces Fines Paid to FINRA Are Not Deductible

Fines pertaining to violations of federal securities laws and certain FINRA rules may not be deducted. The Internal Revenue Service (IRS) in low-level advice recently announced its position that certain fines paid to...more

Derivatives in Review - July 2016

An Overview of Proposed Regulation AT - Orrick attorneys authored an overview of Regulation Automated Trading (known as "Regulation AT") proposed by the Commodity Futures Trading Commission ("CFTC") in the May/June 2016...more

Brexit: Overview of Potential Impact on Derivatives

The process of Brexit will take many years, and the implications for our clients’ businesses will unfold over time. Our MoFo Brexit Task Force is coordinating Brexit-related legal analysis across all of our offices, and...more

Section 83(b) Election Procedures Changed

On July 25, 2016, IRS finalized new regulations that eliminate the requirement for a taxpayer to file a copy of a Section 83(b) election with the taxpayer’s individual income tax return...more

Case Note: Crime Doesn’t Pay and Taxes are Still Due

In a case involving criminal forfeiture of stock option profits, the Court of Appeals for the Federal Circuit has held that no deduction is allowed for $44 million in forfeited stock option gains on which tax was previously...more

IRS Provides Guidance for Making an 83(b) Election

On July 25, 2016, in T.D. 9779, the IRS published final regulations concerning the procedures for making an election under section 83(b) of the Code. The new final regulation, Treas. Reg. §1.83-2, eliminates the requirement...more

Brazil tax court decision on withholding of individual income tax on employee stock options: key takeaways for companies

A recent decision by the Brazilian Federal Administrative Tax Court (CARF) partially settles the debate between Brazilian tax authorities and companies regarding the treatment of employee stock options for purposes of...more

MTC Annual Meeting Update: Market-Sourcing Regulations Presented to Executive Committee

On July 28, the Multistate Tax Commission (“MTC”) held its Executive Committee Meeting. The Executive Committee voted to accept the Uniformity Committee’s recommendations for a taxpayer’s prospective change in its method of...more

Development of the practice on assessing of withholding tax on interest income (coupon yield) payable by a Russian company for...

On 29 June 2016 the Commercial Court of Moscow rendered a decision in the case No. ?40-178650/15-75-1487 under the application of Gazprombank JSC (the “Bank”). The decision contains a number of findings that in future may be...more

Masala bonds - A taste of things to come?

Borrowing by Indian companies from the overseas market or 'External Commercial Borrowings' (commonly referred to as ECBs), is regulated by the Reserve Bank of India (RBI) and is governed by the various rules specified by the...more

Proposed Regulations under Section 355 Clarify Device and Active Trade or Business Requirements for Tax-Free Spin-offs

On July 15, 2016, the U.S. Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published proposed regulations that would modify the device and active trade or business requirements for tax-free...more

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