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Results: 1-10 of 3,504

Tribunal Overturns ALJ and Holds That Bank Must Apply NOLs in Year Taxed on Non-Income Base
  • Morrison & Foerster LLP
  • USA
  • May 4 2016

The New York State Tax Appeals Tribunal has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward deduction to


EU Political Update: 02 - 06 May 2016
  • Clifford Chance LLP
  • European Union, USA
  • May 2 2016

On 26 April 2016, MEPs from the Economic and Monetary Affairs Committee approved a report which outlines the European Parliament's recommendations on


Trade Alert - April 2016, Issue 28 - Ukraine
  • Cadwalader Wickersham & Taft LLP
  • Iceland, Ukraine, USA
  • April 28 2016

Ukraine is seeking to strengthen its ties with the EU, its largest trading partner. Ukraine’s main exports to the EU are raw materials, including iron


IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity
  • Orrick, Herrington & Sutcliffe LLP
  • OECD, USA
  • April 28 2016

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity On April 4, 2016, the IRS and U.S. Treasury Department issued


Another Reason to be Cautious about “Bad Boy Non-Recourse Carve-out Guarantees”
  • Locke Lord LLP
  • USA
  • April 25 2016

On February 5, 2016 the IRS released Chief Counsel Advice Memorandum Number 201606027 (the IRS Memo) concluding that "bad boy guarantees" may cause


Doing Business in North America (Volume 1 - United States)
  • Miller Canfield PLC
  • USA
  • April 23 2016

In choosing to conduct business in the United States, businesses based in other countries should keep in mind that business entities are formed under


EuroResourceDeals and Debt - April 2016
  • Jones Day
  • France, Italy, USA
  • April 21 2016

In In re Berau Capital Resources Pte Ltd, 540 B.R. 80 (Bankr. S.D.N.Y. 2015), the US Bankruptcy Court for the Southern District of New York recently


Polish Legislation Newsletter - March 2016
  • Clifford Chance LLP
  • European Union, Poland
  • April 13 2016

In March the Sejm enacted the Act Amending the Act on the Bank Guarantee Fund and the Act on Cooperative Banks, Associations by Cooperative Banks and


Contentious Commentary - April 2016
  • Clifford Chance LLP
  • Portugal, United Kingdom
  • April 11 2016

The ISDA Master Agreement applies to derivatives transactions in, generally, one of two ways. First, by the parties entering into a long-form


New Jersey Tax Court Rules on Inclusion of Mortgage-Related Receipts in Receipts Factor Numerator
  • Sutherland Asbill & Brennan LLP
  • USA
  • April 11 2016

The New Jersey Tax Court ruled on the sourcing of mortgage-related receipts received by a bank and also held that the Division of Taxation could not