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Firm Profile: Proskauer Rose LLP
Eleven Times Square
(Eighth Avenue & 41st Street)
New York, NY 10036-8299, United States
Phone: 212.969.3000
Fax: 212.969.2900
Areas of Practice
  • Taxation
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Looking Ahead to the 2018 Proxy Season: Preparing for CEO Pay Ratio Rules Disclosure Requirements

As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act enacted in July 2010, Congress directed the Securities and Exchange Commission (SEC) to adopt pay ratio disclosure requiring public companies to disclose…more
 /  Business Organizations, Labor & Employment Law, Securities Law

Zero Dividend Shares are Ordinary Share Capital

The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits…more
 /  Business Organizations, Civil Procedure, Securities Law, Taxation

Failure to Prevent the Facilitation of Tax Evasion: New United Kingdom Corporate Criminal Offence

As mentioned in our July 2017 edition of UK Tax Round Up, the UK has enacted a new corporate criminal offence of failing to prevent the facilitation of tax evasion. The law comes into effect on 30th September 2017, and…more
 /  Business Organizations, Commercial Law & Contracts, Criminal Law, International Law & Trade, Taxation

Conservative Legislative Agenda Set Out in Queen’s Speech

Following the UK general election on 8 June 2017, at which Theresa May’s Conservative party won the largest number of seats but lost its overall majority, the Queen’s Speech setting out the now minority Conservative government’s…more
 /  Elections & Politics, Finance & Banking, International Law & Trade, Labor & Employment Law, Taxation

Proposed Partnership Audit Regulations Reissued in Substantially Identical Form

On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit regime…more
 /  Business Organizations, Taxation

BEPS Update: OECD Multilateral Instrument Signed

On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),…more
 /  International Law & Trade, Taxation

IRS Issues Guidance on “North-South” Transactions

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced…more
 /  Business Organizations, Commercial Law & Contracts, Securities Law, Taxation

Tax Court Rules that Extensions of Variable Prepaid Forward Contracts Do Not Result in Taxable Exchanges

Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not give rise to a taxable exchange to the obligor because a VPFC is solely an…more
 /  Civil Procedure, Commercial Law & Contracts, Finance & Banking, Securities Law, Taxation

Trump Administration Announces Outline of Its Tax Proposal

Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’…more
 /  Business Organizations, Elections & Politics, Taxation

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs…more
 /  Finance & Banking, International Law & Trade, Taxation

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK…more
 /  Business Organizations, Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax…more
 /  Commercial Law & Contracts, Real Estate - Commercial, Real Estate - Residential, Taxation

BEPS: Update on Action 6 on Treaty Benefits

In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and…more
 /  Commercial Law & Contracts, International Law & Trade, Taxation

BEPS: OECD Releases Multilateral Tax Treaty Convention

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on November…more
 /  International Law & Trade, Taxation

Potential for Tax Reform in 2017: Insight from Proposals of the President-Elect and Congressional Republicans

In the U.S. general election held on November 8, 2016, Donald J. Trump was elected to become the 45th President of the United States. Republicans also retained their majorities in both the U.S. House of Representatives and the…more
 /  Commercial Law & Contracts, Elections & Politics, International Law & Trade, Science, Computers, & Technology, Taxation
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