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Key tax considerations in spin-offs
- McDermott Will & Emery
- -
- USA
- -
- April 29 2013
A critical consideration in the disposition of any business is the tax cost. If properly structured, a disposition structured as a spin-off can be
‘Fiscal cliff’ legislation temporarily extends key provisions for businesses
- McDermott Will & Emery
- -
- USA
- -
- January 7 2013
As part of legislation enacted in early 2013 to avert the so-called "fiscal cliff," Congress temporarily extended several beneficial tax provisions for
Year-end legislation extends key provisions for businesses, provides 100 percent expensing for certain assets and enacts new foreign procurement excise tax
- McDermott Will & Emery
- -
- USA
- -
- January 4 2011
As part of legislation enacted at the end of 2010, the U.S. Congress extended several beneficial tax provisions for businesses, including the research credit, active financing exception under Subpart F and look-through rule for payments between controlled foreign corporations
Puerto Rico enacts new excise tax that impacts U.S. companies
- McDermott Will & Emery
- -
- Puerto Rico, USA
- -
- November 3 2010
A temporary excise tax recently enacted in Puerto Rico will have a significant impact on U.S.-based multinational groups conducting, or considering conducting, manufacturing activities in the country
Congress enacts international tax legislation, limits use of foreign credits
- McDermott Will & Emery
- -
- USA
- -
- September 8 2010
On August 10, 2010, President Obama signed the Education Jobs and Medicaid Assistance Act of 2010 into law
Congress extends five-year carryback of 2008 or 2009 NOLs to most businesses
- McDermott Will & Emery
- -
- USA
- -
- November 10 2009
Congress has resurrected a prior Stimulus Act proposal allowing most taxpayers, not just small businesses, to extend the NOL carryback period under section 172 for up to five years for 2008 and 2009 NOLs
IRS expands guidance on application of section 382 to Treasury’s purchase of financial instrument
- McDermott Will & Emery
- -
- USA
- -
- May 21 2009
The IRS expands previous guidance to provide that any purchase of financial instruments under the Emergency Economic Stabilization Act of 2008 will not result in an ownership change under section 382
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