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Internal Revenue Service Debt Securities

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.  
Kramer Levin Naftalis & Frankel LLP

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

Locke Lord LLP

New Tax Rules May Cause Changes in High Yield Deals and Credit Facilities with Upstream Guarantees

Locke Lord LLP on

The details of new tax rules are described in this Locke Lord Quick Study from our tax and finance colleagues. From a capital markets perspective, the new tax rules open up interesting possibilities. For decades, companies...more

Morrison & Foerster LLP

The next chapter - A new bond linking financial returns to environmental or social goals could thrive. But securities law...

Shakespeare’s Juliet may not have ascribed great significance to a name but for securities lawyers and market participants alike there is significance to nomenclature. Social impact bonds, or investments that are intended to...more

A&O Shearman

Focus on Tax Controversy and Litigation - Treasury and IRS Issue Proposed Regulations Imposing Documentation Requirements Under...

A&O Shearman on

In addition to the discussion of the recently proposed regulations which impose new documentation requirements under Section 385, this month’s issue features articles regarding the Circuit Court decision in Chemtech Royalty...more

Fenwick & West LLP

Section 385 Proposed Regulations

Fenwick & West LLP on

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

Alston & Bird

A Reverse Morris Trust Ruling

Alston & Bird on

LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"New Section 355 No-Rule Policies"

On January 2, 2013, the Internal Revenue Service (the Service) released Rev. Proc. 2013-3, its annual list of areas in which it no longer will issue private letter rulings or determination letters (the 2013 No-Rule List). Of...more

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