Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
Will The Debt Ceiling Standoff End Up In Court?
Corporate Law Report - Office Party Holiday Risks, Human Trafficking, the Fiscal Cliff, More
Micah Green on U.S. Fiscal Policy
How Do We Pay For Lower Corp Tax Rates?
Polsinelli Shughart Election Analysis and Legal Insight
Why choose Bennett Jones for your Canadian Cross-Border Income Trust (CBIT)?
What are the tax benefits of a Canadian Cross-Border Income Trust (CBIT)?
Why choose Canada for a Cross-Border Income Trust (CBIT)?
What is a Canadian Cross-Border Income Trust (CBIT)?
Bill on Bankruptcy: Solyndra, Lehman, MF Global, ATP Oil, LSP Energy, Want Ads
Should you Opt-Out of the Voluntary Disclosure Program?
Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers
Cost of Voluntry Asset Disclosure Program
Federal Ministry of Finance: If the capital gain is not taxable in Germany,
the correspondent dividends are taxed.
With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more
On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more
On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more
In recent years, there has been a considerable expansion of the types of companies holding non-traditional real estate assets that have elected to become real estate investment trusts for US federal income tax purposes...more
Hedge fund managers should be aware of two recent U.S. Tax Court memorandum decisions that shed further light on when a taxpayer, such as a hedge fund, is considered to be a "trader" or "investor" for tax purposes -- a...more
On November 5, 2013, the Internal Revenue Service (IRS) issued final regulations relating to the transfer or assignment of certain derivative contracts. The final regulations, which are provided as Treas. Reg. § 1.1001-4,...more
The IRS has issued final regulations on the transfer or assignment of certain derivative contracts. A derivative is a financial instrument that is priced upon a derivation of the value of one or several underlying assets,...more
Welcome to King & Spalding's economic development news bulletin, Investing in
Georgia. In this edition, you will find:
- Ongoing coverage of tax reform proposals, including a report published by the Committee for a...more
As our readers know, foreign investments into the People’s Republic of China (“PRC”) are typically structured through one or more holding companies domiciled in offshore jurisdictions. Planned and implemented properly, an...more
A U.S. shareholder of a controlled foreign corporation (CFC) has gross income on its share of the CFC's subpart F income. This income includes “foreign base company sales income” or FBCSI. ...more
Introduction: Why Post-Issuance Compliance?
Over the past few years, the tax-exempt bond market has been under heightened scrutiny by various regulators, including the Internal Revenue Service...more
On October 4, 2013, California reduced the additional California state income taxes levied on deferred arrangements that violate Section 409A of the Internal Revenue Code. For taxable years beginning on January 1, 2013,...more
On Friday October 3, 2013, Governor Brown signed into law AB 1412, which provides full relief for individuals affected by the decision in Cutler v. Franchise Tax Board, where the California Court of Appeal held that the...more
The European Council Legal Service has issued an opinion that seriously questions the legal validity of the European Commission’s proposals for a financial transaction tax (FTT). The opinion finds that the extraterritorial...more
The new provisions are now in force and allow UK employees to give up certain employment rights in return for shares in their employer (or its parent), but important questions remain unanswered.
On 1 September, the new...more
Yes. You do. That was easy. But perhaps we have gotten ahead of ourselves and we should start at the beginning of the story. While Section 409A is a tax provision, its genesis was the perceived abuse of deferred compensation...more
The much publicised “employee shareholder” status came into effect yesterday, 1 September 2013, offering employers a more flexible way to structure their workforce. The new legislation applies to companies of all sizes, but...more
Long before taxpayer-sponsored bailouts or state-sponsored “resolutions” of financial institutions came to occupy such a prominent place in our collective consciousness, financial institutions relied on hybrid capital...more
Bitcoins are everywhere. Last week, a federal judge in Texas held that the virtual currency qualifies as a form of money and allowed the SEC to charge a promoter of a scheme to invest in bitcoins with violations of the...more
Differing points of view have arisen regarding determining the active participation of S-Corporation shareholdings held in Trust....more
On July 25, the FTB held a public hearing on its proposed revisions to its regulation on intercompany transactions. The changes attempt to fix issues with the current rules governing Deferred Intercompany Stock Accounts...more
The U.S. Internal Revenue Service (IRS) has proposed a new Revenue Procedure (Proposed Revenue Procedure) regarding the application of the wash sale rules under Section 1091 of the U.S. Internal Revenue Code (Code) to...more
A Small Business Investment Company (SBIC) is a privately owned and operated company that makes long-term investments in American small businesses and is licensed by the United States Small Business Administration (SBA)....more
In This Issue:
Regulatory Updates -
SEC Proposes Money Market Reform; SEC Eases Ban on General Solicitation and General Advertising in Certain Private Placements; SEC and CFTC Adopt Joint Rules to Address...more
Welcome to the latest Massachusetts Quarterly Update from Reed Smith. This update for the 2nd Quarter of 2013 includes coverage of a number of corporate excise tax developments, in particular: (i) pending apportionment...more