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What matters: A review of 2011 and 2012
- Kramer Levin Naftalis & Frankel LLP
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- USA
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- April 1 2013
As you know, the last two years have seen a somewhat improved, but by no means robust, business climate. At the same time, structural shifts in the
Passive foreign investment company rules: treatment of income from certain government bonds for purposes of the passive foreign investment company rules
- Sullivan & Cromwell LLP
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- USA
- -
- July 2 2012
In an important notice responding to current economic conditions, the Internal Revenue Service has acknowledged that banks may be holding larger amounts of government securities than they ordinarily would, and that it does not intend this situation to cause them to be treated as “passive foreign investment companies,” a category that may discourage U.S. persons from investing in their shares
FATCA: private equity funds
- Winston & Strawn LLP
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- USA
- -
- June 19 2012
The Foreign Account Tax Compliance Act (“FATCA”) increases the U.S. tax compliance burden for foreign financial institutions (called “FFIs” in FATCA-speak
Financial services legislative and regulatory update - November 14, 2011
- Mintz Levin Cohn Ferris Glovsky and Popeo PC
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- European Union, USA
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- November 14 2011
With two weeks to go, all of Washington continues to try to figure out the ending to the most complicated choose your own adventure story
PA bank shares tax: big news for banks involved in mergers
- Reed Smith LLP
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- USA
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- August 4 2011
Today, the Commonwealth Court decided the Lebanon Valley Farmers Bank case
Capital markets 2011 mid-year report
- Torys LLP
- -
- Canada, USA
- -
- July 27 2011
To date, 2011 has been an exciting year in North American capital markets
New developments affect reporting obligations for U.S. interests in non-U.S. private investment funds
- Schulte Roth & Zabel LLP
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- USA
- -
- March 23 2010
In late February, the Treasury Department (“Treasury”) issued Notice 2010-23 (“Relief Notice”) and Announcement 2010-16 (the “Announcement”), providing additional guidance relating to the filing of Reports of Foreign Bank and Financial Accounts (Form TD F 90-22.1) (“FBAR”) for all years through 2009
Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued
- Proskauer Rose LLP
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- USA
- -
- March 3 2010
On February 26, 2010, the Treasury Department published long-awaited, revised proposed regulations clarifying which taxpayers will be required to file the Report of Foreign Bank and Financial Accounts, Form TD F 90-22
Debt buy-backs - UK taxation change as of 14 October 2009
- Cadwalader Wickersham & Taft LLP
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- USA
- -
- November 2 2009
On 14 October 2009, the UK government announced a major change to the UK tax legislation covering the buy-back of debts
Proposed legislation would reverse benefit to bank acquirers and restrict deductions on losses
- White & Case LLP
- -
- USA
- -
- January 29 2009
Proposed legislation would reverse the recent concession by the United States Department of the Treasury (“Treasury”) that waived the limitation on the deduction of losses of a bank that undergoes an ownership change
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