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Tax Securities

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Unexpected Risks of Early Exercise ISOs

by Dorsey & Whitney LLP on

Companies that permit the grant of early exercise incentive stock options (“ISOs”) do so primarily to limit the impact of the alternative minimum tax (“AMT”). However, due to fairly counterintuitive tax regulations,...more

Turning Tides

by DLA Piper on

Ukraine is typically seen as an emerging country, blighted by crisis. Ukrainians are all gradually helping to change this stereotype. Here we examine key legal reforms aimed at improving the efficiency and safety of...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

China’s infamous shadow banking industry—an $8.5 trillion marketplace that’s sprung up in reaction to the government’s “campaign against financial leverage”—is back and bigger than ever these days....more

French Legal and Regulatory Update – March 2017

by Hogan Lovells on

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e-newsletter, which offers a legal and regulatory update covering France and Europe for March 2017. Please see full...more

Dutch Supreme Court refers questions on withholding tax refunds for foreign investment funds to CJEU

by DLA Piper on

The Dutch Supreme Court has referred preliminary questions on Dutch dividend withholding tax refunds for foreign investment funds to the Court of Justice of the European Union (CJEU). The Dutch Supreme Court wishes to clarify...more

Blockchain and the Law - Overview of token sales and bitcoin property rights

by Perkins Coie on

On March 29, 2017, Perkins Coie partner Dax Hansen and associate Josh Boehm were invited to the Cyber Initiative at Stanford Law School to deliver a presentation on several cutting-edge legal issues relating to blockchain...more

RSU Awards to U.S. Taxpayers Require Careful Review Before Grant

by Dorsey & Whitney LLP on

Recently we blogged about pitfalls and potential adverse tax consequences for U.S. taxpayers with respect to deferred share unit awards that pay out following the participant’s termination of services. But what about...more

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

by Dechert LLP on

CSSF Press Release 17/06 Dated 13 February 2017 - The CSSF confirmed that it follows ESMA on its opinion in relation to the requirements for UCITS share classes....more

Stamp duty changes for all share transfers - including listed companies?

by Dentons on

On 10 March 2017, an urgent bill was passed, with all three readings done in a single Parliament sitting on the same day. A joint press release (the Press Release) was released on the same day by the Ministry of National...more

SEC Issues Final Rules to Make JOBS Act Inflation Adjustments and Amendments to Forms and Rules to Accommodate Emerging Growth...

by Dorsey & Whitney LLP on

On March 31, 2017, the Securities and Exchange Commission (SEC) issued final rules regarding inflation adjustments and other technical amendments under Title I and III of the Jumpstart Our Business Startups (JOBS) Act. Under...more

Finnish Supreme Administrative Court ruled on carried interest in private equity structures

by DLA Piper on

On 16 March 2017, the Supreme Administrative Court (SAC) of Finland issued a ruling on the tax treatment of carried interest in a private equity structure. The SAC ruled that carried interest is taxed as income of the limited...more

Recent Tax Court Cases Serve As Reminder Of Tax Risks Of Shareholder Guarantees Of Loans To S Corporations

by Dickinson Wright on

Two recent Tax Court cases are reminders that shareholder guarantees of loans to an S corporation do not generally create basis that can be used by the shareholder to deduct losses. Under Internal Revenue Code...more

Availability of Tribal Economic Development Bond Allocations

by Holland & Knight LLP on

Based on a recent Internal Revenue Service (IRS) announcement, the Published Value Cap Limit for Tribal Economic Development Bonds (TEDBs) is steadily shrinking...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Further Update on Federal Taxation - Australian Infrastructure Investment and Privatisation

by Jones Day on

Last month, we reported in our White Paper on taxation proposals directed at infrastructure and utility privatisation transactions. Since we wrote, the Commonwealth Treasury ("Treasury") has published a policy paper directed...more

Corporate E-Note - March 2017

by Burr & Forman on

Burr & Forman recently defended the contract manufacturer XYMOGEN, Inc. in a federal jury trial involving a $16,000,000 lost profits claim by a disgruntled former customer. Please see full E-Note below for more...more

Unpacking Your LLC: Tax Considerations in Limited Liability Company Liquidations

by Smith Anderson on

Has your LLC lost its luster? Has it outlived its usefulness as an asset management, asset protection, or, dare we say it, wealth transfer vehicle? Are you tired of discussing the company’s operations with the other owners?...more

Saudi Arabia Update - March 2017

by Dentons on

Legal developments - The Kingdom continues its move towards e-government services - Ministry of Municipal and Rural Affairs considers issuing temporary licenses online for multiple activities - The Ministry of...more

Public Companies Should Consider Shareholder Reapproval of Section 162(m) Performance Compensation Plans Approved in 2012

by Snell & Wilmer on

As public companies continue to prepare for the 2017 proxy season, we wanted to provide a final reminder of an executive compensation related item that might require shareholder approval in 2017. As reported in Part 1 of our...more

IRS Synchs Excise Tax to DOL's Enforcement Policy on Fiduciary Rule

by Burr & Forman on

The IRS released guidance this week announcing that it will not apply IRC § 4975 excise taxes (15% on prohibited transactions) and related reporting requirements “with respect to any transaction or agreement to which the...more

Budget 2017: Changes to Canadian Exploration Expense and Flow-Through Shares

by Bennett Jones LLP on

Canadian exploration expenses (CEE) are certain types of expenses incurred by oil and gas, mining and renewable energy corporations. CEE is 100 percent deductible in the year the expense is incurred. Certain types of CEE also...more

"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

"Key Takeaways: Corporate Governance Series — Key Trends in Executive Compensation, Employment Law and Compensation Committee...

On February 28, 2017, Skadden hosted a webinar titled “Key Trends in Executive Compensation, Employment Law and Compensation Committee Practices.” The Skadden panelists were labor and employment law partner David Schwartz,...more

Indonesian feed-in tariffs – New rules may under-power the renewables sector

by DLA Piper on

Indonesia's new feed-in tariffs (FITs) for renewable energy present a conundrum. Will renewables flourish or fade in the new revenue environment? Investors will not welcome the lower tariffs under the new regime, but state...more

IRS Notice: Conservation Easements for Charitable Giving

by Bryan Cave on

In Notice 2017-10, the Internal Revenue Service recently issued guidance on syndicated conservation easement transactions presumed to be used as tax shelters. This addition to the “listed transactions” under Section...more

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