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Treasury Releases Final DebtEquity Regulations
  • Jones Day
  • USA
  • October 20 2016

On October 13, 2016, the U.S. Treasury Department released final debtequity regulations under section 385 of the Internal Revenue Code aimed

Final Section 385 Treasury Regulations Offer Good News for Most REITs
  • Hunton & Williams LLP
  • USA
  • October 20 2016

On October 13, 2016, the Internal Revenue Service ("IRS") and Treasury Department published final and temporary Treasury regulations (the "Final

Partnership Tax Audit Reform and Private Funds
  • Foley & Lardner LLP
  • USA
  • October 18 2016

The Bipartisan Budget Act of 2015 that was signed into law on November 2, 2015, made extensive changes to the rules that apply to partnership audits

IRS issues final debt-equity rules
  • Dentons
  • USA
  • October 17 2016

On October 13, 2016, the US Internal Revenue Service (IRS) released final and temporary regulations that recharacterize certain debt between related

Guide to Doing Business in Canada: Mergers & acquisitions
  • Gowling WLG
  • USA
  • October 14 2016

Canada is an ideal location in which to establish and grow a business, including by way of mergers and acquisitions. There are a number of advantages

More on Rev. Proc. 2016-44: What Light Is Shed on Net Profits Compensation?
  • Squire Patton Boggs
  • USA
  • October 7 2016

As reported several times in this blog Rev. Proc. 2016-44 significantly expands the opportunities for managementservice contracts that don’t result

Sidley Perspectives on M&A and Corporate Governance - October 2016
  • Sidley Austin LLP
  • USA
  • October 4 2016

In July 2016, a high-profile group of senior executives from major companies and institutional investors published a set of “Commonsense Principles

New Tax Inversion Rules: Good Politics; Bad Business.
  • FTI Consulting Inc
  • European Union, United Kingdom, USA
  • October 3 2016

The new anti-inversion rules may be politically appealing, but they will cause unintended consequences that could actually undermine U.S. businesses

IRS Will Issue Rulings on Spin-off-Related Issues
  • Shearman & Sterling LLP
  • USA
  • September 19 2016

On August 26, 2016, the Internal Revenue Service issued Rev. Proc. 2016-45, which modified the IRS's annual list of issues that the IRS will not issue

The New Partnership Audit RulesWhen to Amend Your Partnership or LLC Agreement
  • Arent Fox LLP
  • USA
  • September 19 2016

The new partnership tax audit rules enacted by Congress on November 2, 2015 could have a dramatic impact on partnerships and their partners (including