The Situation: The Australian Securities and Investments Commission ("ASIC") recently released its report on its corporate finance regulatory activities for the first half of 2019. The Result: While ASIC's report makes...more
This week, we return to two recurring themes of this blog: (I) related party transactions – specifically, transactions between a taxpayer and a corporation controlled by the taxpayer; and (II) what happens when a taxpayer...more
The publication of the Reviewed Broad-based Black Economic Empowerment Charter for the South African Mining and Minerals Industry, 2016 in the Government Gazette on 15 June 2017 (MC17) had and immediate, dramatic effect on...more
The IRS recently provided taxpayers with favorable guidance involving tax-free spin-offs. First, the IRS will resume issuing private rulings that allow a distributing corporation to satisfy debt it issued in anticipation of a...more
On July 15, 2016, the Internal Revenue Service (IRS) released a new revenue procedure, Rev. Proc. 2016-40, providing safe harbors for transactions in which a corporation (Distributing) obtains the requisite control of a...more
On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more