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Results: 1-10 of 253

California Legislature restores and expands qualified small business stock incentives

  • Winston & Strawn LLP
  • -
  • USA
  • -
  • April 11 2014

As of January 2014, the California Legislature has restored and increased opportunities for investors to defer or exclude gains from the sale of

Inversions - upside for acquisitions

  • Kirkland & Ellis LLP
  • -
  • USA
  • -
  • April 10 2014

With U.S. corporate tax rates among the highest in the world, U.S.-based companies with international operations regularly look for structuring

IRS PFIC Regs

  • Hodgson Russ LLP
  • -
  • USA
  • -
  • March 27 2014

The IRS issued definitions and reporting requirements for shareholders of passive foreign investment companies (PFICs) effective December 31, 2013

US investments in Germany 2014 tax aspects

  • Bird & Bird
  • -
  • Germany, USA
  • -
  • March 27 2014

According to 2011 White House figures, US direct investment in Germany has quadrupled since 1989. US exports to Germany support approximately 400,000

New urgency for corporate inversion transactions

  • Cadwalader Wickersham & Taft LLP
  • -
  • USA
  • -
  • March 26 2014

Corporate inversions have constituted an active and successful part of the M&A market in 2013 and early 2014, as acquirors have typically traded up on

Navigating the Russia sanctions: anticipate, don’t react

  • Kurtin PLLC
  • -
  • Russia, USA
  • -
  • March 24 2014

The sanctions imposed on twenty leading Russian officials and businessmen with ties to Russian President Vladimir Putin and one financial institution

Treasury Department proposes to expand anti-inversion rules

  • Cadwalader Wickersham & Taft LLP
  • -
  • USA
  • -
  • March 11 2014

The Treasury Department, in its Fiscal Year 2015 Revenue Proposals (the "Green Book"), has proposed to significantly tighten Section 7874 of the

An unusual FD(?) reorganization

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 1 2014

LTR 201406005 evidently blessed as an F or D reorganization the transfer by a subsidiary of all of its assets to its parent corporation, despite the

Managing riskcaptive insurance companies

  • McDermott Will & Emery
  • -
  • USA
  • -
  • February 26 2014

In every mergers and acquisitions (M&A) transaction, a series of risk management choices must be made. These choices range from "bet the company"

Updated guidance on PFIC and Form 5471 reporting

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 21 2014

In 2010 Congress enacted section 1298(f) with the seemingly simple requirement that each US person who is a shareholder of a passive foreign