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Results: 1-10 of 2,887

从全球视角看附带权益征税
  • King & Wood Mallesons
  • Hong Kong, United Kingdom, USA
  • July 22 2016

附带权益即奖励给成功的基金经理的利润分成其征税方式已成为私募和风投行业长久以来热议的话题随着私募和风投行业在全球范围内不断发展


Taxation of financial institutions
  • Steptoe & Johnson LLP
  • USA
  • July 22 2016

Intermediation between liquid deposits and illiquid investments. Pooling of investments and investment diversity. Types of Bank Organizations


New Proposed Regulations Provide Clarity and Rigidity to Tax-Free Spin-Off Rules
  • Greenberg Traurig LLP
  • USA
  • July 22 2016

If finalized, newly released proposed Treasury regulations may make spin-offs more difficult to accomplish despite providing important clarity. The


New Spin-off Rules
  • Clifford Chance LLP
  • USA
  • July 21 2016

On July 14 and 15, 2016, the Treasury and the IRS issued new guidance on the requirements for tax-free corporate "spin-off" transactions. The


Spin-Off Revenue Procedure Removes a No-Rule Area and Provides Safe Harbors for Unwinding High VoteLow Vote Stock Structures
  • Shearman & Sterling LLP
  • USA
  • July 21 2016

On July 15th, the IRS released Rev. Proc. 2016-40 (the "Rev. Proc.") removing a recent "norule" area with respect to transactions undertaken in


GT’s Quick Guide to Section 338(h)(10) Elections
  • Greenberg Traurig LLP
  • USA
  • July 19 2016

Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80 or more of a target corporation. A 338(h)(10


Qualified Intermediaries and “Dividend Equivalent” Withholding
  • Sullivan & Cromwell LLP
  • USA
  • July 19 2016

The IRS recently released a new draft “qualified intermediary” (“QI”) agreement (the “Proposed QI Agreement”) in Notice 2016-42 (the “Notice”). All


IRS Issues Safe Harbors under Which the IRS Will Not Assert That a Corporation Lacks the Requisite ‘Control’ for Purposes of Section 355(a)
  • McDermott Will & Emery
  • USA
  • July 18 2016

On July 15, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-40. This Revenue Procedure provides safe harbors in which the IRS will


New Guidance Affecting Spinoffs: IRS and Treasury Department Issue New Proposed Regulations
  • Sullivan & Cromwell LLP
  • USA
  • July 18 2016

On July 14 and 15, 2016, the Internal Revenue Service (the “IRS”) and the Treasury Department issued new guidance affecting spinoffs. The first set


Treasury and IRS Issue New Spin-Off Proposed Treasury Regulations On Device and Active Trade or Business Requirements
  • Shearman & Sterling LLP
  • USA
  • July 15 2016

On July 14, 2016, the Treasury Department and the IRS issued proposed regulations under Section 355 on spin-off transactions (the “Proposed