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Top five traps for the unwary in spin-offs

McDermott Will & Emery
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USA
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April 29 2013

A wave of corporate breakups has swept through the United States over the last few years as investors have taken notice of the fact that smaller

IRS to pay medical resident FICA refund claims for tax periods ending before April 1, 2005

McDermott Will & Emery
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USA
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May 3 2012

The Internal Revenue Service (IRS) has begun notifying teaching hospitals that it has completed its review of their medical resident FICA refund claims for tax periods ending before April 1, 2005

Favorable temporary ACA exemption for expatriate health plans

McDermott Will & Emery
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USA
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May 2 2013

Recently issued guidance addresses the unique compliance issues surrounding expatriate health plans under the Patient Protection and Affordable Care

Key tax considerations in spin-offs

McDermott Will & Emery
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USA
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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

IRS capitalized legal fees incurred by pharmaceutical company

McDermott Will & Emery
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USA
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April 15 2013

In a recently released Field Attorney Advice, the Internal Revenue Service (IRS) Office of Chief Counsel concluded that a pharmaceutical company must

Venture funds: don’t fear the LLC

McDermott Will & Emery
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USA
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April 15 2013

It has long been the case that venture funds (classified as partnerships for tax purposes) have insisted that limited liability companies (LLCs

E&P and deduction opportunities for US companies with foreign pension plans

McDermott Will & Emery
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USA
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June 19 2012

It has now been 30 years since the US Congress enacted Section 404A to “rescue” US taxpayers with global operations maintaining large foreign pension plans through branches, disregarded entities, partnerships or controlled foreign corporations

The top five tax traps in M&A transactions

McDermott Will & Emery
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USA
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August 31 2010

The tax consequences of acquisition and disposition transactions can dramatically impact deal value

For private equity investors, Section 1202 may be worth another look

McDermott Will & Emery
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USA
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March 21 2013

Included in the American Taxpayer Relief Act of 2012 (ATRA) are provisions that extended some of the more significant benefits of Internal Revenue

Section 263a regulation falters under the Chevron two-step and Administrative Procedure Act

McDermott Will & Emery
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USA
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June 6 2012

It’s not often that U.S. Treasury Department Regulations are invalidated under the Chevron two-step analysis and the Administrative Procedure Act, but the Federal Circuit recently did just that in Dominion Resources when it invalidated a portion of the Treasury Regulations issued under Section 263A(f

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Search results

Top five traps for the unwary in spin-offs

IRS to pay medical resident FICA refund claims for tax periods ending before April 1, 2005

Favorable temporary ACA exemption for expatriate health plans

Key tax considerations in spin-offs

IRS capitalized legal fees incurred by pharmaceutical company

Venture funds: don’t fear the LLC

E&P and deduction opportunities for US companies with foreign pension plans

The top five tax traps in M&A transactions

For private equity investors, Section 1202 may be worth another look

Section 263a regulation falters under the Chevron two-step and Administrative Procedure Act

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