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Extenders bill already needs renewal

  • Bryan Cave LLP
  • -
  • USA
  • -
  • January 14 2015

On December 19, 2014, President Obama signed the tax extenders bill into law after the bill passed both the House and Senate. Unfortunately, the bill

Tax news and developments - Fall 2013

  • Bryan Cave LLP
  • -
  • China, Germany, USA
  • -
  • December 20 2013

Code Sec. 1031 has been used, albeit inconsistently, for years by savvy owners of fine art to preserve capital by deferring the gain on the sale of

IRS posts final Form 8960 instructions for Net Investment Income Tax

  • Bryan Cave LLP
  • -
  • USA
  • -
  • March 4 2014

The Internal Revenue Service has posted final instructions to Form 8960, Net Investment Income TaxIndividuals, Estates, and Trusts, to its

The Monthly Measurement method: is there a “there”, there?

  • Bryan Cave LLP
  • -
  • USA
  • -
  • March 25 2014

The proposed rules for implementation of the Employer Mandate (aka "Shared Responsibility for Employers Regarding Health Coverage" or "Play or Pay"

Does the U.S.- German double tax treaty also apply to a U.S. limited liability company?

  • Bryan Cave LLP
  • -
  • Germany, USA
  • -
  • April 29 2013

Whenever a U.S. Limited Liability Company ("US-LLC") is involved in cross-border shareholding structures concerning the United States

Five key considerations when drafting a release

  • Bryan Cave LLP
  • -
  • USA
  • -
  • July 3 2014

Separation agreements almost always contain release provisions whereby one or both parties agree to waive claims that they may have against the other

Federal tax consequences of trust modificationreformation: score one for the taxpayer

  • Bryan Cave LLP
  • -
  • USA
  • -
  • June 13 2013

When is a modification or reformation of an irrevocable trust given effect for Federal tax purposes? In each of two recent private letter rulings

Treasury issues revised regulations under Section 871(M)

  • Bryan Cave LLP
  • -
  • USA
  • -
  • March 27 2014

Generally, payments of dividends are sourced based on the residence of the payor while payments on swaps are sourced based on the residence of the

It’s income tax time again . . . But don’t forget about the gift tax return

  • Bryan Cave LLP
  • -
  • USA
  • -
  • March 26 2014

It's that time of the year againtax time! Like it or not, when tax season rolls around it is time for most Americans to add "do taxes" to the

Recognition of income on roll out of split-dollar arrangement

  • Bryan Cave LLP
  • -
  • USA
  • -
  • November 19 2012

The Tax Court in Neff v. Commissioner, TC Memo 2012-244 (8272012) recently ruled on the income tax consequences of the termination of a split dollar life insurance arrangement (“SDLIA”), in ruling that the payment of a discounted amount by the employees on the termination of the SDLIA resulted in the recognition of income to the employees to the extent of the difference between the amount owed to the corporation under the SDLIA and the amount the employees paid