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Administrative Agency Tax Mergers & Acquisitions

Read need-to-know updates, commentary, and analysis on Administrative Agency issues written by leading professionals.

"Challenging the IRS Anti-Inversion Notice: A Hollow Threat"

On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations aimed at blunting certain of the benefits from so-called inversion...more

State Revenue Departments Misapplying Federal Tax Law

by McDermott Will & Emery on

State income tax laws generally build on federal tax law. The typical pattern is to begin the calculation of state taxable income with federal taxable income and then to modify it by adding or subtracting items where state...more

Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office

by Mintz Levin on

Attorney Stephen Gulotta, Managing Member of Mintz Levin's New York office, discusses the importance of advance planning in the sale of privately held companies. ...more

Administrative Law Judge Affirms Holding on Alabama SRLY Rule

On August 15, 2012, Chief Administrative Law Judge Bill Thompson issued his long-awaited SRLY ruling, holding that an Alabama consolidated group was entitled to carry forward certain net operating losses (“NOLs”) incurred...more

State and Local Tax Implications of Reorganizing Business Enterprises

by Morrison & Foerster LLP on

Originally published in State Tax Notes, July 23, 2012. This is the first installment in a series that will examine state and local tax (SALT) questions implicated by the purchase, sale, and reorganization of business...more

The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings

On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final, temporary, and proposed regulations under section 7874, which provides rules governing so-called “inversion transactions.” In...more

The 2011 Form 990: More than Simple Tinkering at the Margins

by McDermott Will & Emery on

While recent changes to the Form 990 make it more reader friendly, filing organizations must carefully review it for substantive changes to determine the impact on their reporting requirements, particularly tax-exempt...more

Recent Compensation Trends In Mergers And Acquisitions And Section 409a

This article discusses the traps for the unwary created by Section 409A of the Internal Revenue Code (“Section 409A”) with respect to current trends in change-in-control compensation for public company executives and the...more

Understanding the difference between: Limited Liability Partnerships (LLP) and Private Limited Company (Pvt. Ltd.)

Since LLP has been introduced in India, apart from incorporating a traditional Limited Liability Company, it has become an option for entrepreneurs, business owners and investors starting new ventures to start their business...more

Killer B Regulations Finalized

by Charles (Chuck) Rubin on

Triangular B reorganizations are often conducted whereby a subsidiary corporation will acquire a target corporation in exchange for stock of the subsidiary’s parent corporation. Throw a foreign corporation into the mix and...more

Update: New IRS Reporting Rules for Stock Splits, Mergers and Acquisitions

Update: The IRS recently came out with a Notice (Notice 2011-18) stating that, for transactions occurring in 2011, penalties will not be imposed against issuers for missing the deadline to file a return or post the tax...more

New Tax Reporting Requirements For Corporate Actions Affecting Stock Tax Basis

Beginning on January 1, 2011, regulations1 issued under Section 6045B of the Internal Revenue Code will require any domestic or foreign corporation that undertakes an “organizational action,” such as a merger, acquisition,...more

Crisis Commission Argues on IRS Assistance for Wachovia

The Financial Crisis Commission has put forth its argument that Wells Fargo & Co’s purchase of Wachovia was with government assistance despite the widely held belief that it was not. The IRS had changed the tax code just...more

Communications Law Bulletin, October 2008

by Morrison & Foerster LLP on

In this issue: *The Month in Brief *FCC Streamlines Satellite Earth Station License Process *California Passes New Broadband and Prepaid Services Laws and Considers Copper Loop Retirement Issues *FCC Clarifies ?Junk...more

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