IRS issues economic substance “guidance” *

USA - October 13 2010
As we reported two issues ago in this publication, the "economic substance doctrine" has been codified.

Co-authors: Arthur Man, Thomas A. Humphreys, Anna T. Pinedo, Remmelt A. Reigersman, Stephen L. Feldman.

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The classroom — fixed-to-floaters *

USA - October 13 2010
Fixed-to-floating rate notes appear to becoming more popular for fixed-income investors lately.

Co-authors: Arthur Man, Thomas A. Humphreys, Anna T. Pinedo, Remmelt A. Reigersman, Stephen L. Feldman.

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Press corner *

USA - October 13 2010
Taxes on sliced bagels?

Co-authors: Arthur Man, Thomas A. Humphreys, Anna T. Pinedo, Remmelt A. Reigersman, Stephen L. Feldman.

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Medicare tax— on the sale of a principal residence? *

USA - October 13 2010
As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8% Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners.

Co-authors: Arthur Man, Thomas A. Humphreys, Anna T. Pinedo, Remmelt A. Reigersman, Stephen L. Feldman.

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Small Business Jobs Act affects source rules for guarantee fees *

USA - October 13 2010
As discussed in our prior client alert "Small Business Jobs Act of 2010—Key Revenue-Raising Provisions," the Small Business Jobs Act of 2010 (signed into law on September 27, 2010) includes $12 billion in tax cuts aimed at small businesses and several revenue raising provisions.

Co-authors: Arthur Man, Thomas A. Humphreys, Anna T. Pinedo, Remmelt A. Reigersman, Stephen L. Feldman.

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