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Results: 1-10 of 1,688

Doing Business in North America (Volume 1 - United States)
  • Miller Canfield PLC
  • USA
  • April 23 2016

In choosing to conduct business in the United States, businesses based in other countries should keep in mind that business entities are formed under


“Bad Boy Guarantee” of Non-Recourse Partnership Debt
  • Sullivan & Cromwell LLP
  • USA
  • April 18 2016

On April 15, 2016, the IRS released a generic legal Advice Memorandum (the “GLAM”) providing an important and helpful clarification of the treatment


Internal Revenue Service Takes a Look at “Bad Boy” Guarantees
  • Dickinson Wright PLLC
  • USA
  • April 18 2016

It is common for LLCs operating (and taxed) as real estate partnerships to obtain nonrecourse financing secured only by the real estate owned by the


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


Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum
  • Morrison & Foerster LLP
  • USA
  • March 22 2016

A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that


The State AG Report Weekly Update February 4, 2016
  • Cozen O'Connor
  • USA
  • February 4 2016

Washington Attorney General Sues State Labor Council for Alleged Campaign Finance Violations. Washington AG Bob Ferguson filed a complaint against


Doing business with native American tribal corporations: some competitive advantages - Fall 2015
  • Greenberg Traurig LLP
  • USA
  • October 15 2015

In an expanding global economy, investors are looking for competitive advantages and more advantageous business environments. Businesses and


Proposed partnership Treasury Regulations consider the guaranteed payment
  • Dechert LLP
  • USA
  • October 7 2015

Proposed regulations were issued under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the "Code"), that address circumstances


Management fee waivers: Treasury Department proposes regulations to address disguised payments for services
  • Schulte Roth & Zabel LLP
  • USA
  • July 28 2015

On July 22, 2015, the Treasury Department released proposed regulations under Section 707 of the Internal Revenue Code of 1986, as amended (the


How the recent Supreme Court term will affect business
  • Sullivan & Cromwell LLP
  • USA
  • July 23 2015

In Mach Mining, the Supreme Court considered whether and to what extent courts may review the Equal Employment Opportunity Commission’s attempt to