Podcast: Cum-Ex Dividend Trade Investigations
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Venture Capital Trends: East Meets West – Lewis Geffen, Co-chair, Venture Capital Practice
What Individuals and Businesses Need to Know About the American Taxpayer Relief Act
Liberty Global Inc. (“LGI”) avoided tax from the sale of a Belgian subsidiary by claiming a dividends received deduction for the entire amount of $2.6 billion in gain. The government challenged this result on economic...more
The EU Commission published a public consultation based on its initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, which includes a system for tax authorities to exchange...more
The shock waves from the German authorities’ tax evasion investigation into cum-ex transactions, a complex form of dividend arbitrage, continue to be felt throughout Europe. A large number of UK and European financial...more
Big news out of the online lending space, as Lending Club’s chair and CEO—Renaud Laplanche—has resigned after an internal review “showed a violation of the company’s business practices” related to sales of $22 million in...more
Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more