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Internal Revenue Service › Debentures

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Cadwalader, Wickersham & Taft LLP

Crossing the U.S. Trade or Business Line

Cadwalader, Wickersham & Taft LLP on

YA Global Investments, LP (“YA Global”), a foreign investment fund that provided funding to portfolio companies in exchange for stock, convertible debentures, promissory notes and warrants, engaged U.S.-based Yorkville...more

Rivkin Radler LLP

Tax Losses Realized During the Crypto Winter

Rivkin Radler LLP on

Debacle- Understanding the etymology of a word often enables us to better understand or appreciate its use in contemporary speech. For example, the word “crypto” is derived from the Greek word “krypto,” which describes...more

McDermott Will & Emery

Federal Circuit Narrowly Interprets Limitations Period for Foreign Tax Credit Refund Claims

McDermott Will & Emery on

In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...more

Morrison & Foerster LLP

MoFo Tax Talk Volume 8, Issue 1

Morrison & Foerster LLP on

In This Issue: - IRS Rules Debentures Are Part of Straddle; Interest Non-Deductible - Stock Abandonment Produces Ordinary Loss - Tax Consequences of Negative Interest Rates - Renewed Discussion of a...more

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