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IRS adds certain spin transactions to the “no rule” list
  • Latham & Watkins LLP
  • USA
  • September 30 2015

On September 14, 2015, the United States Treasury Department (the Treasury) and the United States Internal Revenue Service (the IRS) issued Notice

New temporary regulations narrow the application of the Subpart F active rents and royalties exception
  • McDermott Will & Emery
  • USA
  • September 24 2015

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation 1.954-2T

Treasury, IRS issue final F reorganization regulations
  • Steptoe & Johnson LLP
  • USA
  • September 18 2015

Today, Treasury and the IRS issued final regulations addressing the qualification of a transaction as a corporate reorganization under section

The Treasury and the IRS issue spin-off revenue procedure and notice announcing no-rule areas that are under study
  • Shearman & Sterling LLP
  • USA
  • September 16 2015

On September 14th, the IRS released Rev. Proc. 2015-43 (the "Rev. Proc.") announcing new "no-rule" areas with respect to spin-offs involving

IRS formally expands no-rule policy to include certain spin-off rulings
  • Baker Botts LLP
  • USA
  • September 15 2015

On September 14, 2015, the Internal Revenue Service ("IRS") issued Rev. Proc. 2015-43, which formally expanded the IRS no-rule policy to include the

What every fund manager wants to know about the ECI rules (but is afraid to ask)
  • Greenberg Traurig LLP
  • USA
  • September 8 2015

Short of a tornado or a cataclysmic earthquake obliterating midtown Manhattan or Greenwich, CT, there is little that offshore fund managers fear more

Funds talk: September 2015
  • Kramer Levin Naftalis & Frankel LLP
  • USA
  • September 1 2015

On Aug. 3, 2015, President Obama announced the Environmental Protection Agency’s (EPA) final Clean Power Plan rule, which will sharply cut emissions

Change-in-control preparedness: part 1
  • Morgan Lewis & Bockius LLP
  • USA
  • August 28 2015

In light of robust merger and acquisition activity, companies should review their compensation and benefits programs to understand the effect that a

Consolidated return update
  • Pepper Hamilton LLP
  • USA
  • August 28 2015

In the last six months, the U.S. Department of the Treasury has issued two sets of proposed regulations that provide needed guidance in the area of

New regulations aimed to stop private equity managers from converting fee income to capital gains
  • Montgomery McCracken Walker & Rhoads LLP
  • USA
  • August 27 2015

It's well-known that private equity managers often pay capital gain rates on their "carried interest" - typically, a 20 percent profit allocation for