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Results: 1-10 of 310

US Senate Finance Committee unanimously approves FIRPTA reforms

  • Squire Patton Boggs
  • -
  • USA
  • -
  • February 20 2015

On February 11, 2015, the Senate Finance Committee approved a bill that would make significant changes to the Foreign Investment Real Property Tax

Is a distribution of previously taxed income “exempt from tax”?

  • Bilzin Sumberg Baena Price & Axelrod LLP
  • -
  • USA
  • -
  • February 18 2015

A U.S. shareholder of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of the CFC’s subpart F

New regulations likely to slow 'inversion' deal activity

  • Ropes & Gray LLP
  • -
  • USA
  • -
  • January 28 2015

Over the past several years the frequency and notoriety of so-called 'inversion' transactions have increased dramatically. An inversion

Challenging the IRS anti-inversion notice: a hollow threat

  • Skadden Arps Slate Meagher & Flom LLP
  • -
  • USA
  • -
  • January 28 2015

On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations

New year, new potential for UK and European private placements

  • Ropes & Gray LLP
  • -
  • European Union, United Kingdom, USA
  • -
  • January 26 2015

Week two of the New Year marked a significant step in the development of the European Private Placement Market: The Loan Market Association (LMA

Ruling demonstrates potential for inversion rules to apply in inbound structures

  • Bilzin Sumberg Baena Price & Axelrod LLP
  • -
  • USA
  • -
  • January 21 2015

In Private Letter Ruling 201432002 (the "PLR"), the IRS ruled that a foreign-to-foreign "F" reorganization did not implicate the Section 7874

M&A across the Atlantic: what a United States buyer should expect in the United Kingdom

  • Winston & Strawn LLP
  • -
  • United Kingdom, USA
  • -
  • January 8 2015

In 2014, according to reports, M&A activity reached pre-crisis levels with more than $2.4 trillion of completed deals in the United States and

Pelosi puts focus on inversions

  • Steptoe & Johnson LLP
  • -
  • USA
  • -
  • January 5 2015

In a letter to the Democratic caucus, House Minority Leader Nancy Pelosi (D-CA) wrote that corporate inversions would continue to be a focus of House

Recent IRS anti-inversion proposals: Notice 2014-52

  • Baker Botts LLP
  • -
  • USA
  • -
  • December 17 2014

A corporate transaction that has received considerable publicity in recent months is the so-called "inversion" where a public U.S. company migrates

Tax Court characterizes technology executive’s merger proceeds as ordinary income

  • Mintz Levin Cohn Ferris Glovsky and Popeo PC
  • -
  • USA
  • -
  • November 18 2014

On October 30th, the U.S. Tax Court ruled that a key executive of a technology company acquired by Google for $93 million was required to report a