News & Analysis as of

Virtual Currencies: International Actions and Regulations

This chart is provided by Perkins Coie LLP’s Decentralized Virtual Currency industry practice group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does...more

Treasury Committee takes evidence on BoE Bill

The House of Commons Treasury Select Committee has held an evidence session as part of its inquiry into the Bank of England Bill (BoE Bill), currently intended to be brought forward in autumn 2015. Among other things...more

Altera: Tax Court Invalidates Section 482 Regulation on Administrative Law Grounds

In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm’s-length...more

IRS Announces Intent to Tax Transfers to Partnerships

On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"),[1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more

The IRS Takes Aim at De-Risking of Defined Benefit Plans

Many defined benefit plan sponsors are looking for ways to reduce the on-going liability and the volatility of the annually required contributions to their defined benefit plans, which is sometimes referred to as...more

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more

Treasury Imposes Toll Charge on Some Transfers of Assets by U.S. Taxpayers to Partnerships with Their Foreign Affiliates

On August 6, 2015, the Treasury and the IRS issued Notice 2015-54, which implements a Clinton-era tax provision intended to prevent U.S. taxpayers from using the partnership provisions of the Code to shift built-in gain on...more

The End Of An Era? IRS Announces The End Of The 5-Year Determination Letter Remedial Amendment Cycles

On July 21, 2015 the IRS announced that the staggered 5-year determination letter remedial amendment cycles for individually designed qualified retirement plans will be eliminated as of January 1, 2017. Generally, this means...more

The “Cadillac Tax”: A Tankful of Issues: McGuireWoods Healthcare Reform Guide: Installment No. 52

This is the 52nd in a series of WorkCite articles concerning the Patient Protection and Affordable Care Act and its companion statute, the Health Care and Education Reconciliation Act of 2010 (referred to collectively as the...more

Treasury Consultation Paper – Another Step Towards Crowd-Sourced Equity Funding

On 4 August 2015, the Treasury of the Australian Government released a consultation paper, facilitating crowd-sourced equity funding and reducing compliance costs (Consultation Paper). This follows the previous discussion...more

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

Tax Policy Update

The number of days until the U.S. House of Representatives returns from August recess. The Senate is in this week to tackle procedural motions for legislation related to cybersecurity and Planned Parenthood. The Senate is...more

"Tax Court Invalidates Stock-Based Compensation Amendment in Altera"

On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg. §1.482-7(d)(2) (2003 Amendment) that required controlled participants in a...more

Treasury Department: Tell Us More About Online Marketplace Lending

Why it matters - Raising the possibility of regulation, the Department of the Treasury has published a Request for Information (RFI) regarding online marketplace lending (also called peer-to-peer lending), seeking...more

Banking Disputes Quarterly - Q2 2015

Welcome to the summer issue of Banking Disputes Quarterly, keeping you informed about the latest news and legal developments in banking disputes. In On the Horizon we look ahead to an important appeal to be heard by...more

Iranian Bank Entitled To Recover Damages For Losses Suffered As A Result Of Unlawful Treasury Restrictions

We consider here the judgment of the High Court (Commercial Court) in Mellat v HM Treasury [2015] EWHC 1258 (Comm) (6 May 2015). The judgment relates to three preliminary issues of law in a claim by an Iranian bank, Bank...more

UK Treasury releases Consultation Paper under MiFID II

Following the Financial Conduct Authority’s (“FCA”) release of its discussion paper on implementation of the revised Markets in Financial Instruments Directive (“MiFID II”) on 26 March 2015, the UK Treasury released on 27...more

FCA And PRA Senior Managers And Certification Regime –March 2016 Implementation Date Announced

Rules due to come into force in March 2016 Yesterday HM Treasury announced the commencement date for the new FCA and PRA Senior Managers and Certification Regime. Relatively limited information has been released, but...more

Review Of FCA And PRA Enforcement Processes: HM Treasury Findings And Recommendations

On 18 December 2014, HM Treasury published a final report following the review that it has undertaken of enforcement decision-making processes at the FCA and the PRA. Originally published in Practical Law on February...more

FIO Focus No. 69 - House Passes TRIA Reauthorization Legislation

On December 10, 2014, the House approved a bill to reauthorize the Terrorism Risk Insurance Act (TRIA) for six years. The vote was 417-7. The compromise legislation, worked out between Senator Charles Schumer (D-NY) and...more

UK Treasury Calls for Information on Digital Currencies

On November 3, the UK Treasury issued a call for information on digital currencies, including Bitcoin. Views are being solicited from the public, the financial services industry, regulators, and law enforcement agencies....more

UK Implementation of AIFMD – Transitional Period Extended

In December 2013, HM Treasury announced that the transitional period allowing existing U.K. alternative investment fund managers (AIFMs) to continue managing their alternative investment funds (AIFs) without receiving...more

They think it's all over…

The late, great Ken Wolstenholme, if asked about the House of Commons Treasury Committee Report on Private Finance 21, could well say the same for PF2. Just as Costa Rica's Bryan Ruiz hammered home the final nail in the...more

Treasury releases its submission to the inquiry

The Department of Treasury has released its submission to the Financial Systems Inquiry. The 90 page submission concludes that the financial system has performed well since the Wallis inquiry but there is room for the system...more

Australian Treasury Considers Controversial Reforms To Extend Sales Tax To Overseas Online Purchases

In recent months, the Australian federal Treasury has come under intense pressure from local retailers and state treasures to extend the Australian goods and services tax (GST) to overseas-purchased goods and services. On 27...more

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