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PLR Confirms Section 332 Coverage of Check-The-Box Election of Wholly-Owned Subsidiary

When an existing corporation makes a check-the-box election to be a disregarded entity, this is treated as a corporate liquidation. This can result in gains to the electing entity under Code Section 337 pursuant to a deemed...more

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more

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