Tax Law, Securities Law

Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk [Video]

by Bloomberg Law on 5/22/2013

May 22 (Bloomberg) -- AMF Bowling Worldwide Inc. and Ahern Rentals Inc. are prime examples of the frothy market where junk-bond investors are fearless in the face of risk, as Bloomberg Law's Lee Pacchia and Bloomberg News...more

N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

by Lindsay LaCava, Arthur R. Rosen | McDermott Will & Emery on 5/22/2013

A New York administrative law judge recently held in Matter of C.V. Starr & Co., Inc. that income received by a taxpayer from its ownership of common stock was investment income. In so holding, the ALJ addressed an important...more

Legal Alert: Tax Court Finds Indirect Prohibited Transaction in IRA

by Adam Cohen, Mikka Gee Conway, Jonathan Goldman, Carol McClarnon, Alice Murtos, Joanna Myers, Vanessa Scott, W. Mark Smith, Rich Sun, William Walderman, Carol Weiser | Sutherland Asbill & Brennan LLP on 5/22/2013

In Peek v. Commissioner (May 9, 2013), the U.S. Tax Court ruled that two taxpayers had engaged in an indirect “prohibited transaction” with their individual retirement accounts (IRAs) when they provided personal guarantees...more

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 5/22/2013

In a Written Ministerial Statement made in UK Parliament on 21 May 2013, Treasury Economic Secretary Sajid Javid MP announced the Treasury’s intention to make a crucial and very welcome clarification to the recent HMRC Brief...more

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

IRS Approves New Rules To Minimize Taxes Related to M&A Transactions

by Craig Circosta, Karen McConnell, Wayne Strasbaugh | Ballard Spahr LLP on 5/14/2013

The Internal Revenue Service recently adopted long-awaited regulations intended to provide a new means of minimizing taxes in M&A transactions. The newly adopted regulations take effect on May 15, 2013, under Section 336(e)...more

"Shares for Rights: Over-Sold or Under-Appreciated?"

by James Anderson, Helena Derbyshire | Skadden, Arps, Slate, Meagher & Flom LLP on 5/14/2013

In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...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

Basics Of Stock Redemptions

by David Gair | Looper Reed & McGraw, P.C. on 5/10/2013

Closely held corporations often have issues come up about succession planning and also about how to structure transactions in the most tax advantageous way possible. Corporate redemption of a shareholders stock is always...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

Small and Mid-Size Companies: Beware of Increased Cybersecurity Threats of Sensitive Tax Information

by Helen Christakos, Brendan Lund | Carr, McClellan, Ingersoll, Thompson & Horn -... on 5/3/2013

Small and mid-size companies electronically transmit an increased amount of sensitive financial information via the Internet to comply with tax compliance obligations....more

It’s Like Déjà Vu – All Over Again – NSW Defers the Abolition of Stamp Duty

by Philip Diviny, Marise Fraser, Murray Landis | K&L Gates LLP on 5/2/2013

Abolition of NSW duties deferred again - The NSW Government has indicated that the abolition of Inter-Governmental Agreement taxes, including duties on: - marketable securities (shares and units) - ...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

Do You Want to Start A Business? Top 10 Questions & Answers For Business Start-Ups

by Ian Scott | Scott Legal Services, P.C. on 4/23/2013

When starting a new business, our clients often have several questions and more often than not their questions are the same. This article summarizes some of key questions and answers that our clients have asked us....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

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Tax Law › Securities Law

Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk [Video]

N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

Legal Alert: Tax Court Finds Indirect Prohibited Transaction in IRA

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

IRS Issues Final Regulations Treating Qualified Stock Dispositions as Asset Sales

IRS Approves New Rules To Minimize Taxes Related to M&A Transactions

"Shares for Rights: Over-Sold or Under-Appreciated?"

At Last: Final Regulations Issued Under Section 336(e)

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

Basics Of Stock Redemptions

Verbatim: Global Compliance - Quarterly Newsletter: Spring 2013

Small and Mid-Size Companies: Beware of Increased Cybersecurity Threats of Sensitive Tax Information

It’s Like Déjà Vu – All Over Again – NSW Defers the Abolition of Stamp Duty

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

No Happy Trails For Victorville Tax Increment Bond Financing

Options Industry Opposes Market-To-Market Tax Proposal

What Every Private Equity Fund Manager Should Know About ERISA

Do You Want to Start A Business? Top 10 Questions & Answers For Business Start-Ups

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

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

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

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

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

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

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

Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk [Video]

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