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Results: 1-10 of 1,485

Taxation of financial institutions
  • Steptoe & Johnson LLP
  • USA
  • July 22 2016

Intermediation between liquid deposits and illiquid investments. Pooling of investments and investment diversity. Types of Bank Organizations


New Proposed Regulations Increase Scrutiny on Related-Party Debt
  • Dechert LLP
  • USA
  • June 30 2016

New rules recently proposed by the U.S. Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") would re-characterize purported


Sidley Perspectives on M&A and Corporate Governance - June 2016
  • Sidley Austin LLP
  • USA
  • June 10 2016

The exposure of corporate directors to shareholder derivative suits relating to their obligations to provide "risk oversight" to the company may turn


Proposed Regulations on Related-Party Debt Instruments Would Result in Dramatic Adverse Tax Consequences
  • Shearman & Sterling LLP
  • USA
  • June 3 2016

On April 4, 2016, the US Department of the Treasury and the Internal Revenue Service proposed regulations under section 385 of the Internal Revenue


Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions - With Retroactive Effect!
  • Reed Smith LLP
  • USA
  • May 4 2016

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the


Section 385 Proposed Regulations
  • Fenwick & West LLP
  • USA
  • April 29 2016

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under 385 of the Code. Issued the same day as the anti-inversion temporary


Trade Alert - April 2016, Issue 28 - Ukraine
  • Cadwalader Wickersham & Taft LLP
  • Iceland, Ukraine, USA
  • April 28 2016

Ukraine is seeking to strengthen its ties with the EU, its largest trading partner. Ukraine’s main exports to the EU are raw materials, including iron


IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity
  • Orrick, Herrington & Sutcliffe LLP
  • OECD, USA
  • April 28 2016

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity On April 4, 2016, the IRS and U.S. Treasury Department issued


New tax rules treat related party debt as stock and impose strict documentation rules
  • Hogan Lovells
  • USA
  • April 15 2016

On April 4, the IRS and Treasury issued proposed regulations under section 385 of the Internal Revenue Code that treat related party debt as stock


Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
  • Caplin & Drysdale, Chartered
  • USA
  • April 5 2016

In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require