News & Analysis as of

Securities Tax Administrative Agency

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

Private equity’s top ten issues for the next president

by Thompson Coburn LLP on

Many of the issues on the next President’s plate have unique resonance within the private equity world. Here is our list of the top ten private equity issues that the new President and Congress may tackle in the upcoming...more

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

by McDermott Will & Emery on

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

"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

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

by Dechert LLP on

EU Passes New Council Directive to Implement “EU-FATCA" - The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more

What is a Security? Even the SEC Can’t Always Tell

On February 27, 2015, an Administrative Law Judge (ALJ) determined that, contrary to claims by the SEC, interests in an LLC that invested in conservation easements as a tax deduction mechanism were not “securities” within the...more

Did the IRS Just Help or Hurt the Bitcoin Economy?

by Mimesis Law on

Apr. 1, 2014 -- Houman Shadab, Associate Professor at New York Law School, talks with Lee Pacchia about recent developments in the bitcoin economy....more

Investing In Georgia: Economic Development Newsletter - August 2013

by King & Spalding on

Welcome to King & Spalding's economic development news bulletin, Investing in Georgia. In this edition, you will find: - A Client Alert regarding recent SEC enforcement actions againsta School District - A new...more

N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

by McDermott Will & Emery on

A New York administrative law judge recently held in Matter of C.V. Starr & Co., Inc. that income received by a taxpayer from its ownership of common stock was investment income. In so holding, the ALJ addressed an important...more

Congress Extends Exclusion for Investors in Qualified Small Businesses

by Baker Donelson on

Among the taxpayer-favorable aspects of the American Taxpayer Relief Act of 2012 (Act), the 100 percent exclusion from gross income of gain on the sale of Qualified Small Business Stock (QSBS), provided for in section 1202 of...more

Annual Notices for ISOs and ESPPs due January 31, 2013

by Ropes & Gray LLP on

Each January, companies that grant incentive stock options (ISOs) are required to provide notices to current and former employees who exercised ISOs during the preceding calendar year. Similar notices must be given to current...more

FinCEN Announces Third Extension for Certain FBAR Filers

by Morgan Lewis on

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

Investment Management Legal + Regulatory Update -- December 2012

by Morrison & Foerster LLP on

In This Issue: Regulatory Updates - FSOC, FSB Turn Up Heat on SEC on Money Market Fund Reforms; SEC Staff: Beware of BDC Joint Transactions; SEC Reports 3,000 Whistles Blown in FYI 2012; Over 1500 Private Fund Advisers...more

Foreign Taxpayers Can Benefit Despite Proposed Regulations

by Bilzin Sumberg on

Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more

MoFo New York Tax Insights - Volume 3, Issue 12 - December 2012

by Morrison & Foerster LLP on

In This Issue: Court Holds Television Programming Is Included in the Property Factor Regardless of Delivery Method; ALJ Upholds Retroactive Application of Stock Option Regulations; Petition Found Untimely Under Special...more

CFTC Issues First Set of Mandatory Clearing Determinations and Time-Limited No-Action Relief

On November 28, the Commodity Futures Trading Commission (CFTC) issued final clearing determinations (Final Determinations) with respect to four classes of interest rate swaps (IRS) and two classes of credit default swaps...more

Financial Services Quarterly Report - Third Quarter 2012

by Dechert LLP on

In This Issue: - Commodity Pool Operators and Commodity Trading Advisers: Practical Advice for Fund Managers Outside the United States p. 1 - Recent Developments in the Regulatory Framework of the PRC Investment...more

IRS Issues Final Treasury Regulations Expanding Definition of "Traded on an Established Securities Market" and Liberalizing Rules...

On September 12, 2012, the Internal Revenue Service (the “IRS”) issued Final Treasury Regulations (the “Final Regulations”) that clarify the circumstances that cause property to be treated as “traded on an established market”...more

Final U.S. Regulations Clarify When Property Is Deemed Publicly Traded for Purposes of Determining the Issue Price of a Debt...

by Dechert LLP on

The Internal Revenue Service (IRS) has issued final regulations clarifying when property will be considered publicly traded for purposes of determining the issue price of a debt instrument. The determination of the issue...more

Private Funds In Focus - Fall 2012

by Proskauer Rose LLP on

In This Issue: - I Want You To Want Me – Achieving a Successful First Closing - SEC Proposes Rule Amendments To Permit General Solicitation in Private Offerings - STOCK Act Presents New Compliance Concerns...more

Determining the Issue Price of a Debt Instrument: Final Treasury Regulations Clarify When Property Is Publicly Traded

by White & Case LLP on

On September 12, 2012, the US Internal Revenue Service (the “Service”) released final regulations (the “Final Regulations”) detailing when property is publicly traded for purposes of determining the issue price of a debt...more

"Treasury Promulgates Final Regulations on Publicly Traded Debt Instruments"

On September 12, 2012, the Department of the Treasury (Treasury) promulgated important final regulations (the Regulations) that clarify and expand the circumstances in which a debt instrument is to be treated as traded on an...more

IRS Amends Temporary Treasury Regulations under Section 871(m)

On August 31, 2012, the U.S. Internal Revenue Service (the “IRS”) amended Temporary Treasury Regulations (the “Temporary Regulations”) under Section 871(m) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”),...more

Hong Kong Capital Markets Quarterly News -- July 2012

by Morrison & Foerster LLP on

In This Issue: SFC Notes Poor Quality Listing Applications; Regulation of Sponsors in Hong Kong; Class Action Reform; New Listing Decisions; New Guidance Letters; Enforcement News; and Regulatory Watch. Excerpt...more

Financial Services Quarterly Report - Second Quarter 2012

by Dechert LLP on

In This Issue: - DIFC Funds: A New Investment Vehicle for the Middle East p. 1 - An Analysis of the EU and U.S. Regulations Affecting OTC Derivatives p. 4 - Enhancing the Investment Advisory Contract Review...more

Startup Act 2.0 – Making The 100% QSB Stock Exemption Permanent

by Davis Wright Tremaine LLP on

Good news for startups. A bill has been introduced in the Senate (S.3217) and an identical bill has already been introduced in the House, titled Startup Act 2.0 which, among other things, would make the 100% exclusion from...more

86 Results
View per page
Page: of 4

Follow Securities Updates on:

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.