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Internal Revenue Service Private Placements

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.  
Cozen O'Connor

IRS Releases New Issue Price Rules

Cozen O'Connor on

On December 9, 2016, the Internal Revenue Service (the IRS) released new regulations under Section 148 of the Internal Revenue Code of 1986, as amended, (referred to herein as the code) regarding the determination of the...more

Orrick, Herrington & Sutcliffe LLP

Final Treasury Regulations Defining Issue Price

For a variety of reasons related to arbitrage, it often is important to identify the "issue price" of tax-exempt bonds with precision and certainty. Existing Treasury Regulations generally allow the "issue price" of publicly...more

Bracewell LLP

Final Issue Price Regulations Significantly Change Current Rules

Bracewell LLP on

On December 9, 2016, the IRS released final Treasury Regulations (the “Final Regulations”) relating to the “issue price” of tax-exempt bonds for purposes of arbitrage investment restrictions. Although, on balance, an...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - July 22, 2013

SEC and EU Supervisory Cooperation for Asset Management Industry - On July 19, the SEC announced that it signed various memoranda of understanding with the financial regulators of 25 member states of the EU and 3...more

Miller & Martin PLLC

SEC Eliminates Ban on General Solicitation in Private Offerings

Miller & Martin PLLC on

On July 10, 2013, the SEC took the following actions that are likely to have a significant impact on hedge funds, private investment funds and other companies that raise capital through private offerings of securities...more

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