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Recently Issued Final, Temporary and Proposed Treasury Regulations Regarding the Allocation of Partnership Liabilities and Disguised Sales
  • Morrison & Foerster LLP
  • USA
  • October 21 2016

On October 5, 2016, the Internal Revenue Service ("IRS") and Treasury Department published final regulations (the "Final Regulations"), temporary

Minimizing Federal Income Tax on Sale of Qualified Small Business Stock
  • Dickinson Wright PLLC
  • USA
  • October 17 2016

A taxpayer who is considering the sale of certain stock may have the opportunity to exclude or defer part or all of the gain on such sale. To be

There is life after death...of the Bottom-Dollar Guarantee
  • Seyfarth Shaw LLP
  • USA
  • October 14 2016

On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other

Proposed Regulations Could Negatively Impact Family-Controlled Entities
  • Stoll Keenon Ogden PLLC
  • USA
  • October 12 2016

The IRS has proposed new regulations that will substantially impact family-controlled entities. Specifically, the regulations will affect determining

IRS Issues Regulations on Disguised Sale Rules and Allocation of Partnership Liabilities
  • Sullivan & Cromwell LLP
  • USA
  • October 11 2016

The Treasury Department and the Internal Revenue Service (the “IRS”) recently issued final, temporary and proposed regulations (the “Final Regulations

Revenue Procedure 2016-44 Expands Management Contract Safe Harbor
  • Barnes & Thornburg LLP
  • USA
  • October 6 2016

On August 22, the Internal Revenue Service released Revenue Procedure 2016-44, which changes the management contract safe harbors contained in

Sidley Perspectives on M&A and Corporate Governance - October 2016
  • Sidley Austin LLP
  • USA
  • October 4 2016

In July 2016, a high-profile group of senior executives from major companies and institutional investors published a set of “Commonsense Principles

IRS Expands Safe Harbors for Private Management Contracts
  • Bowditch & Dewey
  • USA
  • October 4 2016

With the recent release of Revenue Procedure 2016-44, the IRS has expanded the safe harbors under which 501(c)(3) institutions can permissively enter

Final FAR Rule Will Increase Suspension and Debarment Oversight and Activity - What Does it Mean for Contractors?
  • Venable LLP
  • USA
  • October 3 2016

On September 30, 2016, and effective as of the same day, the Department of Defense, the General Services Administration and the National Aeronautics

New Proposed Regulation Affects Transfers of Family Business Interests
  • Kegler Brown Hill + Ritter
  • USA
  • October 3 2016

The Treasury recently issued Proposed Regulation 2704, which eliminates valuation discounts. A valuation discount allows you to transfer a larger