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Business Taxes Subsidiaries

Barnea Jaffa Lande & Co.

New Israeli Court Ruling on Artificial Transactions

A recent court ruling in the Shalam Packaging Products Group case addressed claims made by the Netanya tax assessor. The assessor argued the group executed a restructuring solely to reduce its tax liabilities by offsetting...more

Farrell Fritz, P.C.

Corporate Spin-Offs: The “Active Trade Or Business” And The Collection Of Income

Farrell Fritz, P.C. on

Keep On Reading- Over the last few months, we’ve been working on a number of transactions that involve the division of a closely held corporation or partnership. In each instance, the impetus for the division has been...more

Dechert LLP

Brexit Preparations for Private Equity Firms

Dechert LLP on

The Current Status of Brexit - On 29 March 2017 the United Kingdom (UK) gave notice under Article 50 of the Treaty on the European Union that it intended to leave the European Union (EU). The UK’s departure (so-called...more

McDermott Will & Emery

Favorable Guidance from the New Jersey Tax Court on the ‘Unreasonable’ Exception to the Related-Party Intangible Expense Add-back

In a recent decision, the New Jersey Tax Court provided some long-awaited guidance on the “unreasonable” exception to the state’s related-party intangible expense add-back provision. In BMC Software, Inc v. Div. of Taxation,...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Pillsbury Winthrop Shaw Pittman LLP

Five Things about the IRS’s Proposed Regulations on the Spinoff Device and Active Business

On July 14, 2016, the Internal Revenue Service (IRS) proposed long-anticipated regulations tightening the “device” and “active trade or business” tests that are necessary for a corporation to distribute a subsidiary in a...more

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