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On February 8, 2012, the IRS issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that build upon prior FATCA notices issued by the IRS
On September 13, 2010, the Internal Revenue Service (IRS) issued proposed regulations (the "Proposed Regulations") on the federal income tax classification of certain "series organizations" (e.g., certain domestic series limited liability companies, series partnerships, series trusts, protected cell companies and similar arrangements, and certain foreign series or cell companies engaged in the insurance business
In 2000, the Anschutz Company (the “Taxpayer”) held appreciated publicly traded stock (through a qualified subchapter S subsidiary) that it wanted to monetize without triggering taxable gain, while simultaneously protecting itself from any future declines in the price of such stock
