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Results: 1-10 of 2,837

No alternative to nexus: parent's royalty addback does not eliminate licensing subsidiary's New Jersey filing obligation
  • Sutherland Asbill & Brennan LLP
  • USA
  • August 27 2015

The New Jersey Tax Court ruled that the Division of Taxation ("Division") properly required a foreign (non-New Jersey domesticated) corporation to


Treasury releases guidance for contributions of appreciated property to partnerships with related foreign partners
  • McDermott Will & Emery
  • USA
  • August 25 2015

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the


Treasury releases guidance for contributions of appreciated property to partnerships with related foreign partners
  • McDermott Will & Emery
  • USA
  • August 25 2015

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the


Domestic partnership agreements: financial disclosures and privacy
  • Carlton Fields Jorden Burt
  • USA
  • August 24 2015

To reduce risk of later attack on the domestic partnership agreement, domestic partners should make fair and reasonable financial disclosures to each


Proposed regulations require significant entrepreneurial risk for a service partner's income to be a distributive share
  • McDermott Will & Emery
  • USA
  • August 18 2015

On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A


Treasury releases notice addressing transactions involving related-party partnerships
  • Skadden Arps Slate Meagher & Flom LLP
  • USA
  • August 17 2015

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing


IRS announces rules on transfers to foreign partnerships
  • Alston & Bird LLP
  • USA
  • August 17 2015

On August 6, 2015, the IRS issued Notice 2015-54 (the Notice), describing regulations under Section 721(c) meant to ensure that gain is recognized


A sea change for waive-rs? - Proposed Regulations address tax treatment of management fee waivers
  • Dechert LLP
  • USA
  • August 14 2015

The U.S. Treasury Department ("Treasury") and the Internal Revenue Service (the "IRS") have issued proposed regulations under Section 707(a)(2)(A) of


Treasury issues Proposed Regulations addressing management fee waivers and other disguised payments from partnerships for services
  • Paul Hastings LLP
  • USA
  • August 12 2015

On July 22, 2015, the Treasury Department released proposed regulations regarding disguised payments from partnerships for services (the "Proposed


New restrictions on property transfers to controlled partnerships with foreign related partners
  • Sullivan & Cromwell LLP
  • USA
  • August 12 2015

On August 6, 2015, the Internal Revenue Service (the “IRS”) issued Notice 2015-54 (the “Notice”) announcing the intention to issue regulations (the