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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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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

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain debt…more
 /  Commercial Law & Contracts, Mergers & Acquisitions, Securities Law, Taxation

Proposed New UK Penalties Regime Precipitated by CRS

Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities…more
 /  Commercial Law & Contracts, Taxation

IRS Updates Ruling Policy on Corporate Business Purpose and Device Requirements under Section 355

The U.S. Internal Revenue Service (“IRS”) released Revenue Procedure 2016-45 (the “Revenue Procedure”) on August 26, 2016, permitting taxpayers once again to seek private letter rulings on issues of “corporate business purpose”…more
 /  Business Organizations, Commercial Law & Contracts, Mergers & Acquisitions, Taxation

IRS Eliminates Requirement to Submit Copy of Section 83(b) Elections with Tax Return

The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted…more
 /  Finance & Banking, Securities Law, Taxation
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