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Results: 1-10 of 2,761

SALT Implications of Proposed Section 385 DebtEquity Regulations
  • McDermott Will & Emery
  • USA
  • May 18 2016

On April 4, 2016, without warning, the US Department of the Treasury proposed a new set of comprehensive regulations under section 385. There had


U.S. Tax Structures Utilized in Connection with Foreign Investment in U.S. Real Estate
  • Kelley Drye & Warren LLP
  • USA
  • May 17 2016

U.S. real estate is expected to attract a record amount of foreign investment in 2016. The U.S. real estate market is perceived as a safe haven in


New Treasury Regulations Make Inversions More Difficult and Alter the Treatment of Debt Instruments Between Related Companies
  • Kramer Levin Naftalis & Frankel LLP
  • USA
  • May 17 2016

Corporate inversions have been at the forefront of discussions regarding international tax reform. In its most recent attempt to curb inversions, on


In a Taxpayer Friendly Reasonable Compensation Case Independent Investor Test Explained
  • Sirote & Permutt PC
  • USA
  • May 16 2016

In a taxpayer friendly decision, H. W. Johnson, Inc., T. C. Memo 2016-95, issued on May 12, 2016, the Tax Court appears to adopt a 10 return on


Proposed Debt-Equity Regulations Have Dramatic Implications for Corporate Tax Planning and Compliance
  • McDermott Will & Emery
  • USA
  • May 12 2016

On April 4, 2016, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury)without advance warningreleased proposed


Sun Capital Update: US Private Equity Funds Liable for Multiemployer Plan Withdrawal Liability of Portfolio Company
  • Mayer Brown LLP
  • USA
  • May 12 2016

On March 28, 2016, in a much-anticipated decision, the US District Court for the District of Massachusetts issued its ruling in Sun Capital Partners


Key Takeaways: Changes Will Impact Investment in US Real Estate
  • Skadden Arps Slate Meagher & Flom LLP
  • USA
  • May 6 2016

On May 4, 2016, Skadden presented the seminar "How FIRPTA and REIT Changes Will Impact Investment in US Real Estate." Congressman Joseph Crowley, D-N


After the FATCA exchange, foreign investment returns will not be the same
  • Foodman CPAs & Advisors
  • USA
  • May 5 2016

From this moment forward, a U.S. taxpayer ought to recognize that IRS will have knowledge of a taxpayer's financial assets outside of the U.S. that


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


Seal the Deal: Four Steps to Effective FCPA Acquisition Due Diligence & Integration
  • Paul Hastings LLP
  • USA
  • May 4 2016

Overtaking records set pre-economic crisis in 2007, 2015 was a banner year for corporate acquisitions with more than $3.8 trillion in global deal