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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
Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued
- Proskauer Rose LLP
- -
- 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
New developments affect reporting obligations for U.S. interests in non-U.S. private investment funds
- Schulte Roth & Zabel LLP
- -
- 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
PA bank shares tax: big news for banks involved in mergers
- Reed Smith LLP
- -
- USA
- -
- August 4 2011
Today, the Commonwealth Court decided the Lebanon Valley Farmers Bank case
New guidance allows greater use of built-in losses in bank M&A deals
- Hunton & Williams LLP
- -
- USA
- -
- October 10 2008
The Treasury Department and the IRS have issued favorable guidance under Internal Revenue Code Section 382 for banks engaging in merger and acquisition activities, as well as certain capital-raising efforts
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
Planning for bank reorganizations
- Alston & Bird LLP
- -
- USA
- -
- November 1 2008
The Treasury plans to invest up to $250 billion to recapitalize the U.S. banking system by buying non-voting preferred stock and warrants to purchase common stock from a large number of banks, thrifts, bank holding companies and savings and loan holding companies
FATCA: private equity funds
- Winston & Strawn LLP
- -
- 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
What matters: A review of 2011 and 2012
- Kramer Levin Naftalis & Frankel LLP
- -
- USA
- -
- 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
Major tax incentive for bank purchases: IRS eliminates the limitation on banks' built-in losses post-purchase
- Jones Day
- -
- USA
- -
- October 8 2008
On September 30, the IRS issued a notice that creates a major tax incentive for buying or making major investments in banks
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