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Safe Harbors Covered Transactions

Kramer Levin Naftalis & Frankel LLP

IRS Denies Deductibility of Sell-Side Advisory Fees

In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller (the PE Seller),...more

WilmerHale

New Commerce Rule Covering ICTS Transactions Involving Foreign Parties

WilmerHale on

A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more

Steptoe & Johnson PLLC

CFIUS & Foreign Investment in Real Estate

Steptoe & Johnson PLLC on

The Committee on Foreign Investment in the United States (CFIUS) is authorized to review certain transactions involving foreign investment in the United States to determine the effect of such transactions on national...more

Akin Gump Strauss Hauer & Feld LLP

New CFIUS Law: Key Issues Affecting the Energy Sector

• FIRRMA broadens the scope of a CFIUS review beyond transactions that could result in a foreign person gaining the ability to control a U.S. business. Consequently, more energy deals could be captured through expanded...more

Troutman Pepper

New IRS Guidance Offers Insight Regarding Covered Transactions Under the Transaction Cost Regulations

Troutman Pepper on

When the IRS released the transaction cost regulations of Treas. Reg. 1.263(a)-5, a new term was created: “covered transaction.” Unlike the treatment of a covered transaction in a tax shelter context, which is generally...more

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