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Section 355 Spin-Off Developments: Clarification of “Predecessors” and “Successors”
  • Paul Hastings LLP
  • USA
  • January 12 2017

Despite the numerous and complex requirements associated with a valid Section 355 spin-off a qualifying distribution under Section 355 is one of the

Applying the Look-Through Rules in Determining 'Investment Partnership' Status Under Section 721(b)
  • Pepper Hamilton LLP
  • USA
  • January 5 2017

Many taxpayers choose partnership structures (including LLCs taxed as partnerships) to operate their businesses

Déjà vu for Comcast in California: Win on Unitary Business, Loss on Termination Fee
  • Baker McKenzie
  • USA
  • January 4 2017

In ComCon Prod. Servs. I, Inc. v. Cal. Franchise Tax Bd., Cal. Ct. App., No. B259619 (December 14, 2016), the California Court of Appeals, Second

Private Fund ReportSummary of Key DevelopmentsWinter 2016
  • Paul Hastings LLP
  • Cayman Islands, USA
  • January 3 2017

This continues to be a time of rapid change for the private investment funds industry, as the Securities and Exchange Commission (the “SEC”), the

New Rules Significantly Impact Disclosure Obligations of Certain Wholly Owned Foreign Subsidiaries
  • Paul Hastings LLP
  • USA
  • December 23 2016

Foreign-held domestic disregarded entities and their owners will be subject to increased disclosure under final U.S. Treasury Regulations which

The Bond Bandwagon
  • Murtha Cullina LLP
  • USA
  • December 19 2016

Are you ready to jump on the tax-exempt bond bandwagon? Over the last eight years, the landscape of tax-exempt bond financing has changed and more

The Impact of New U.S. Partnership Audit Rules on Investment Partnerships in the U.S. and Abroad: Hidden Mines in the Road to Increased Tax Revenue
  • Dechert LLP
  • USA
  • December 19 2016

The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership

Surge of Guidance on Tax Treatment of Certain Rights under IRC Section 1234A
  • Loeb & Loeb LLP
  • USA
  • December 16 2016

IRC Section 1234A of the Internal Revenue Code has emerged from its relative obscurity and been the subject of several important cases

Tax Plans Compared (December 2016) Corporate Tax
  • Caplin & Drysdale, Chartered
  • USA
  • December 16 2016

It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes President-Elect Trump's proposal and

What Exactly Does a Trump Presidency Mean for Private Equity?
  • Hogan Lovells
  • USA
  • December 8 2016

As unpredictable as Donald Trump was as a candidate, the impact of his Presidency seems equally difficult to forecast. As a candidate, Trump’s