News & Analysis as of

Tax Securities

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

Is a Series LLC Right for Your Business?

by Mintz Levin on

The Series limited liability company (the “Series LLC”) is more nuanced than an ordinary limited liability company, and for the right user, it provides flexibility that will streamline administration better than other...more

Tax planning for private corporations and their shareholders - converting income into capital gains

by Dentons on

On October 19, 2017, the Department of Finance Canada issued a news release advising that it will not move ahead with proposed measures intended to target the conversion of income into capital gains. The announcement is the...more

The Acquisition and Leveraged Finance Review – US

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – Russia

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – Spain

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – Germany

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – England and Wales

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

End and refund of the French 3% tax on distributions

by White & Case LLP on

The French Constitutional Court rules that the 3% contribution on distributions is unconstitutional - On 6 October, 2017, the French Constitutional Court, in its decision (n°2017-660 QPC), held that the 3% contribution on...more

Financial Services Quarterly Report - Third Quarter 2017: Luxembourg Developments

by Dechert LLP on

Luxembourg recently has taken a number of actions in connection with the transposition or implementation of various EU directives and regulations, respectively, into national law. The Luxembourg government deposited a bill of...more

IRS Releases New Public Approval Proposed Regulations

On September 28, 2017, the Internal Revenue Service (IRS) withdrew previous proposed regulations and released new proposed regulations (the “Proposed Regulations”) relating to public approval requirements for tax exempt...more

FERC Holds Certain Passive Equity Interests in Public Utilities Are “Non-Voting Securities” for Purposes of Section 203 of the...

On October 4, 2017, in a decision with significant implications for the energy project finance community, the Federal Energy Regulatory Commission (FERC or the “Commission”) granted a petition for declaratory order filed by...more

FERC Loosens The Reins On Tax Equity Under Section 203 Of The Federal Power Act

by Morrison & Foerster LLP on

On October 4, 2017, the Federal Energy Regulatory Commission (FERC) continued to clear its case backlog and issued a declaratory order that draws a road map clarifying that certain tax equity investments in FERC-regulated...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Uber’s Board of Directors has officially voted to realign the power balance at the company, reducing the clout of ousted CEO Travis Kalanick, and setting the stage for a stock sale to SoftBank. Oh yeah, and prepping for that...more

Tax Equity Investors Wave Goodbye to FPA Section 203

by Stoel Rives LLP on

Tax equity investments, and potentially other passive investments, in renewable energy just became that much easier to make. Today, in response to a petition for declaratory order filed in January 2017 by a coalition of...more

Final Regulations on PRIs Make for Inspirational Reading for Family Foundations

It is not often that you can find inspiration within the Treasury regulations. But if you are a family foundation looking for innovative ways of pursuing your charitable mission, you will come away from reading the nineteen...more

When Disaster Strikes: IRS Guidance Gives Employers Additional Options for Assisting Employees Hit by Hurricanes Harvey and Irma

by Foley & Lardner LLP on

When Hurricanes Harvey and Irma made landfall in Texas and Florida, they gave rise not only to widespread property damage, but to a humanitarian disaster as well. The massive storms have left scores dead and thousands...more

Relief for Hurricane Victims

by Ary Rosenbaum on

Thanks to the damage caused by Hurricane Harvey and Hurricane Irma, the Internal Revenue Service (IRS), Department of Labor (DOL), and the Pension Benefit Guaranty Corporation (PBGC) have granted extensions of certain...more

2018 Dutch Tax Plan - changes to Dutch dividend withholding tax

by DLA Piper on

The Dutch Ministry of Finance has published the 2018 Budget and, in connection with it, the 2018 Tax Plan. The 2018 Tax Plan contains a number of already anticipated changes to Dutch tax legislation effective as of January 1,...more

IRS Issues Proposed Guidance on the Definition of Registered Form

by Dentons on

On September 15, 2017, the Internal Revenue Service (IRS) issued proposed regulations (REG-125374-16) amending the definition of obligations that are in registered form to take into account current market practices and...more

Asset Management Regulatory Roundup - September 2017 - Issue 6

by Dechert LLP on

A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details on Brexit: Impact on cross-border financial services contracts; cryptocurrency: initial...more

Major GST/HST changes affecting investment limited partnerships

by Dentons on

On September 8, 2017, the Department of Finance Canada released proposed amendments to the Excise Tax Act (“ETA”) that could deem certain payments from “investments limited partnerships” to its general partner (“GP”), which...more

The Trump threat to 401(k) and the reality of it

by Ary Rosenbaum on

When Donald Trump was elected President last November, there were quite a few people who promised gloom and doom as if it was the end of our republic. Despite the tweets and the drama, that really hasn’t panned out yet. Many...more

Desperate for Offsetting Tax Revenue, Trump looks to Tax your 401(k) and Remove your deduction for Mortgage Interest

by Bowditch & Dewey on

Desperate for an accomplishment in this first year of Republican control of the federal government, the Trump administration is floating two ideas that seem on their faces to be non-starters. One, taxing 401(k) contributions...more

401(k)/403(b) Loan Borrowers – Check Your Paystubs!

by Foley & Lardner LLP on

A recent tax court case, Louelia Salomon Frias, v. Commissioner, TC Memo 2017-139, illustrates why it is good practice to verify that employee loan repayments have been timely deducted. Plan Loan Requirements. An employer...more

Internal Revenue Service Provides Helpful Relief to Hurricane Victims

Announcement 2017-11 (Announcement) provides that a tax-qualified employer retirement plan may treat a distribution to a current or former employee covered by the Announcement as on account of hardship or an unforeseeable...more

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