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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

Stay in LLC Structure and Go Public Using an UP-C Structure
  • Montgomery McCracken Walker & Rhoads LLP
  • USA
  • September 12 2016

In the "old days" if your business was in an LLC classified for tax purposes as a partnership and you thought you wanted to take your company public

Doing Business in Australia
  • DLA Piper LLP
  • USA, Australia, Global, OECD
  • September 7 2016

Australia is a great place to do business, offering a powerful combination of economic, legal and geographic advantages. Our 25 years of

Tax Alert for foreign investors looking at U.S. investments
  • Jeffer Mangels Butler & Mitchell LLP
  • USA
  • September 7 2016

It does not matter whether foreign individuals are investing in U.S. property and hoping to become residents in the U.S., or are planning to invest

Outlook For Fall & Lame Duck
  • Mintz Levin Cohn Ferris Glovsky and Popeo PC
  • USA
  • August 30 2016

As summer ends and we look ahead to cooler weather, a historic presidential election, and a legislative and regulatory calendar that has numerous

Court Gives Energy Transfer the Right to Walk Based on its Counsel’s Inability to Deliver the Required Tax Opinion
  • Cooley LLP
  • USA
  • August 24 2016

In a rare decision involving unusual facts, the Delaware Court of Chancery held that a buyer (Energy Transfer Equity, L.P.) had the right to terminate

IRS Issues New Management Contract Safe Harbors
  • Ropes & Gray LLP
  • USA
  • August 23 2016

Almost 20 years ago, the IRS released Rev. Proc. 97-13, outlining multiple safe harbors under which a management contract would not result in private

Business Law for Startups: Important considerations for startup businesses
  • Pitblado LLP
  • USA
  • August 22 2016

Decided to take the plunge on a new business idea? Or maybe you’ve already got your toes in the water, and you’re thinking about diving off the board

IRS Releases Temporary and Proposed Rules for Partnerships That Want to "Opt in" to New Partnership Audit Regime
  • Steptoe & Johnson LLP
  • USA
  • August 4 2016

Today the IRS released temporary regulations pursuant to section 1101(g)(4) of the Bipartisan Budget Act of 2015 (BBA), providing the time, form, and