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Results: 1-10 of 73

First Circuit Extends Actavis to Non-Cash Payments
  • McDermott Will & Emery
  • USA
  • July 19 2016

In a decision joining a wave of other courts, the US Court of Appeals for the First Circuit extended the Supreme Court of the United States'Actavis


Understanding which deadlines are extended by the recent IRS guidance for hybrid plans
  • McDermott Will & Emery
  • USA
  • November 16 2011

In October 2011, the U.S. Department of the Treasury and the Internal Revenue Service issued Notice 2011-85, announcing their intent to extend certain requirements applicable to hybrid pension plans such as cash balance plans


Understanding which deadlines are extended by the recent IRS guidance for hybrid plans
  • McDermott Will & Emery
  • USA
  • November 10 2011

The U.S. Department of the Treasury and the IRS recently extended certain requirements applicable to hybrid pension plans


Supreme Court rules SPD does not trump plan document, but emphasizes availability of equitable remedies where employer misleads
  • McDermott Will & Emery
  • USA
  • June 20 2011

The Supreme Court of the United States in the CIGNA decision confirms, in what may be hailed as a victory for plan sponsors, that information contained in a summary plan description does not itself constitute the “terms” of a benefit plan for purposes of filing claims for benefits


New Puerto Rico tax code means changes for qualified retirement plans
  • McDermott Will & Emery
  • USA, Puerto Rico
  • March 28 2011

The Commonwealth of Puerto Rico recently adopted a new Internal Revenue Code (PR Code) that contains numerous changes to sections governing qualified retirement plans


SEC, DOJ continue to enforce FCPA cases involving China and joint ventures
  • McDermott Will & Emery
  • USA, China
  • January 14 2011

China's reputation as an emerging world economy has garnered the attention of US law enforcement, including the US Securities and Exchange Commission and the US Department of Justice, which has increased its prosecution of violations of the Foreign Corrupt Practices Act


Congress passes bill extending Section 1603 grant and other energy-related incentives
  • McDermott Will & Emery
  • USA
  • December 17 2010

The U.S. Congress recently passed a bill extending the Section 1603 grant program for one year, prolonging certain credits for biodiesel producers and both continuing and expanding first-year bonus depreciation


Service denies tax deferral and long-term capital gains through basket option transaction
  • McDermott Will & Emery
  • USA
  • December 10 2010

Advice Memorandum 2010-005, released on November 12, 2010, sets out the Internal Revenue Service's position on whether the purchased call option described therein should be respected as an option; treated as another form of a derivative transaction; or recast as, in substance, tax ownership of the underlying basket of securities


Achieving a smooth stock basis
  • McDermott Will & Emery
  • USA
  • November 30 2010

In a helpful recent private letter ruling, the Internal Revenue Service illustrated a method allowing multinational corporations seeking tax-efficient ways to repatriate offshore cash to avoid the obstacle posed by Johnson v. United States


Recent IRS “North-South” rulings
  • McDermott Will & Emery
  • USA
  • September 30 2010

Recent private letter rulings by the IRS illustrate the broad scope of tax planning available with respect to internal restructurings of controlled groups