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Treasury Clarifies That Partners Working for a Disregarded Entity Owned by a Partnership are Self-Employed
  • Sullivan & Cromwell LLP
  • USA
  • May 3 2016

Today, the Treasury Department issued proposed and temporary regulations clarifying that partners providing services to a disregarded entity owned by


Follow-Up: Can You Amend Your Stock Plan to Allow Tax Withholding up to the Maximum Statutory Rate?
  • Winston & Strawn LLP
  • USA
  • May 3 2016

Yesterday, I blogged on the question that many companies are asking: can we amend our Stock Incentive Plan to allow tax withholding above the minimum


What To Do When Your Board Goes Global
  • Baker & McKenzie
  • USA
  • May 3 2016

We are seeing an accelerating trend among U.S. companies to add non-U.S. residents to their Board of Directors. This makes sense: as more and more


Another Warning to Mind the Non-GAAP
  • Drinker Biddle & Reath LLP
  • USA
  • May 3 2016

As we have previously reported, over the past few months, SEC officials and numerous other observers have voiced concern about the pervasive and


Proposed Regulations Would Treat Certain Related-Party Debt Instruments Issued on or After April 4, 2016 as Stock for Federal Tax Purposes
  • Vorys, Sater, Seymour and Pease LLP
  • USA
  • May 3 2016

The IRS recently issued proposed regulations that, if finalized, would treat debt instruments between related persons as stock under certain


“Catch-Up” Distributions to Holders of Profits Interest
  • Berger Singerman LLP
  • USA
  • April 29 2016

It is common for a “profits interest” to be granted to a service-provider in a partnership or a limited liability company (“LLC”) taxed as a


How Will My Business Be Taxed?
  • Fox Rothschild LLP
  • USA
  • April 29 2016

Starting a business can be both exciting and stressful for any new entrepreneur, and perhaps nothing adds more initial stress than the word “taxes.”


IRS Reverses Itself on Treatment of 'Bad Boy Guarantees'
  • Kramer Levin Naftalis & Frankel LLP
  • USA
  • April 26 2016

IRS Reverses Itself on Treatment of 'Bad Boy Guarantees' In February 2016, the IRS released an internal memorandum concluding that typical 'bad boy


State Tax Fallout From Federal Proposed Related-Party Debt Regulations
  • Sutherland Asbill & Brennan LLP
  • USA
  • April 26 2016

Recently proposed Treasury regulations under IRC 385 would create sweeping changes to the federal income tax treatment of related-party debt. The


Partnerships Must Respond to New Audit Rules
  • Carlton Fields
  • USA
  • April 25 2016

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax