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Corporation or LLC? Business Organizations for Tech Startups.

One of the first actions you will take with your startup is to organize your company a separate legal entity to protect yourself from personal liability for the company’s debts. In the tech startup context, you’ll typically...more

Pension Investment Management Services - with or without VAT?

A significant cost of running a defined benefit pension scheme historically has been the VAT on investment management services. However, HMRC has recently confirmed that a European court case means employers may now recover...more

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

Dodd-Frank at 4: Where do we go from here?

Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more

German Investment Taxation – Reform Ahead

The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

Financial Services Quarterly Report - Second Quarter 2015: OECD Discussion Draft on BEPS: Funds’ Treaty Access under Threat

The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more

Changes in the UK Tax Treatment of Carried Interest

In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

Proposed Regulations Issued On Management Fee Waivers

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more

Treasury Department and IRS Release Proposed Regulations on Management Fee Waivers

On July 22, 2015, the Treasury Department and the IRS released proposed regulations regarding fee-waiver arrangements commonly used by private investment funds. If finalized, the new rules would recharacterize certain...more

This Week In Securities Litigation

The SEC filed three actions following-up on its settled proceeding against Oppenheimer for selling millions of shares of unregistered penny stocks. Each individual settled with the agency. In addition, the Commission brought...more

New Tax Rules To Encourage Foreign Investment Into Australia

Effective 1 July 2015, the new “investment manager regime” provides a much simplified tax system for inbound foreign investors, and should be a welcome change for foreign investors who struggle with the complexities of the...more

IRS Issues Notices Regarding Certain Structured Transactions

Parties that enter into “basket option contracts” and “basket contracts” should be aware that the IRS is likely to challenge such transactions and that they have a new obligation to report the transactions to the IRS or face...more

New Nevada Commerce Tax Effective July 1, 2015

While not purporting to give specific advice on Nevada tax law, the following is a summary of some of the general principals underlying the new tax law. A new Nevada Commerce Tax (“NCT”) was signed into law by Nevada Governor...more

Private Equity Newsletter - Summer 2015 Edition: Indian Private Equity: Taxation and Trends

With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year,...more

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

Luxembourg Infrastructure Investment Vehicles - New Brochure - The Association of the Luxembourg Fund Industry (ALFI) has issued new technical guidelines regarding “Luxembourg Infrastructure Investment Vehicles”,...more

Financial Services Quarterly Report - Second Quarter 2015: Countdown to 1 July 2015: Accessing China and Australia via Hong Kong’s...

On 1 July 2015, two significant developments in the Asian funds space will come into effect. Hong Kong’s Mutual Recognition of Funds Scheme (MRF) with the PRC will – for the first time – allow international managers to...more

Ticking all the Right Boxes! Irish Collective Asset Management Vehicles Act 2015 Signed into Law

The eagerly anticipated Irish Collective Asset-management Vehicles Act 2015 (the “ICAV Act”) was signed into law in March 2015 and the first Irish Collective Asset-management Vehicles (“ICAVs”) have been authorised by the...more

Orrick's Derivatives in Review - June 2015

NYDFS Finalizes BitLicense Regulations - On June 3, 2015, the New York Department of Financial Services released its final BitLicense regulations, which it described as "the first comprehensive framework for regulating...more

Kruger: FX Derivatives Gains/Losses Taxed Only When Realized

In Kruger Incorporated v. The Queen (2015 TCC 119), the Tax Court held that the taxpayer could not value its foreign exchange options contracts on a mark-to-market basis, with the result that certain losses were not...more

Income Tax & Crowdfunding

Income tax may not be front of mind when starting a crowdfunding campaign, but early consideration of the issues could prevent a panic-inducing call from the Australian Taxation Office. The choice of crowdfunding model...more

Launch of Mutual Recognition of Funds Between Mainland China and Hong Kong

On 22 May 2015, the Securities and Futures Commission of Hong Kong (SFC) and the China Securities Regulatory Commission (CSRC) signed a Memorandum of Regulatory Cooperation on Mainland-Hong Kong Recognition of Funds, which...more

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

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

First Marblehead Requests U.S. Supreme Court Review In SINAA Sourcing Appeal

In a case of interest for any taxpayer with substantial securitization activities, First Marblehead Corporation and Gate Holdings, Inc. have requested United State Supreme Court review of a recent determination of the...more

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