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Results: 1-10 of 754

When a shareholder gives equity to employees: how’s that taxed exactly?
  • Bryan Cave LLP
  • USA
  • October 28 2015

On October 22, 2015, Twitter, Inc., and its CEO, Jack Dorsey, entered into a Contribution Agreement pursuant to which Dorsey contributed to Twitter


Five key considerations when drafting a release
  • Bryan Cave LLP
  • USA
  • July 3 2014

Separation agreements almost always contain release provisions whereby one or both parties agree to waive claims that they may have against the other


TEGE Announces New Information Document Request Management Process
  • Bryan Cave LLP
  • USA
  • November 22 2016

The Tax Exempt and Government Entities Division of the Internal Revenue Service has issued new internal guidance for its agents on issuing


Does the U.S.- German double tax treaty also apply to a U.S. limited liability company?
  • Bryan Cave LLP
  • Germany, USA
  • April 29 2013

Whenever a U.S. Limited Liability Company ("US-LLC") is involved in cross-border shareholding structures concerning the United States


Federal tax consequences of trust modificationreformation: score one for the taxpayer
  • Bryan Cave LLP
  • USA
  • June 13 2013

When is a modification or reformation of an irrevocable trust given effect for Federal tax purposes? In each of two recent private letter rulings


Deferred developer fees
  • Bryan Cave LLP
  • USA
  • May 5 2015

Questions continue to be raised regarding whether developers should document the obligation to pay deferred development fees with a note. Section


PEOs: A remedy for ACA reporting requirements?
  • Bryan Cave LLP
  • USA
  • January 21 2016

Signed into law in December 2014 and effective January 1, 2016, the Small Business Efficiency Act ("SBEA") provides welcome federal statutory


Reporting target’s deductions in an acquisition
  • Bryan Cave LLP
  • USA
  • April 29 2013

Corporate clients often want a transaction to close at the beginning or end of the day. Generally, the reason for choosing the beginning or end of


IRS rules no fault does not mean no penalty in IRA rollover snafu
  • Bryan Cave LLP
  • USA
  • August 13 2013

At first blush, Chief Counsel Advice Memorandum CCA 201313025, may seem overly harsh. After all, the taxpayer was relying on information provided


Automatic 30-Day Extension of Due Dates for Participant Statements and Reinstatement Good-Faith Compliance Standard Granted!
  • Bryan Cave LLP
  • USA
  • November 21 2016

On Friday, IRS and the Department of Treasury issued Notice 2016-70 granting an automatic 30-day extension for furnishing 2016 Forms 1095-B, Health