Insights

 
Our lawyers produce a wealth of substantive, timely and practical resource materials for our clients and friends of the firm. Listed separately below are client memos and alerts, articles and books, and podcasts.
March 13, 2020 U.S. Supreme Court Rejects Operating Subsidiaries’ Presumptive Right to Tax Refunds in Bankruptcy
Client Memorandum
September 13, 2019 Proposed Changes on Loss Carryforwards Are a (R)BIG Deal for M&A
Client Memorandum
December 20, 2017 Davis Polk Previews the New Tax Regime
Client Memorandum
July 17, 2017 Court Holds Non-U.S. Investor Is Not Taxable on Sale of U.S. Operating Partnership Interest
Client Memorandum
December 2, 2016 Setting the Stage for Comprehensive Tax Reform
Client Memorandum
October 14, 2016 Final and Temporary Section 385 Regulations
Client Memorandum
April 11, 2016 Treasury Issues New Anti-Inversion Guidance
Client Memorandum
April 11, 2016 Treasury Proposes Overhaul of Intercompany Debt Rules
Client Memorandum
January 8, 2015 IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States
Client Memorandum
December 9, 2013 New Proposed and Final Regulations Address Withholding on “Dividend Equivalents”
Client Memorandum
January 20, 2012 New Regulations Address Withholding on “Dividend Equivalents”
Client Newsflash
July 23, 2010 Tax Court Rules on Variable Prepaid Forwards and Stock Lendings
Client Memorandum
December 9, 2009 House to Consider Bill Containing Carried Interest Proposal, Ban on Bearer Bonds and Updated FATCA Rules
Client Memorandum
September 23, 2009 IRS Releases Internal Memorandum Regarding Lending in the United States by Foreign Persons
Client Newsflash
May 4, 2009 Administration's Proposals Regarding the Taxation of U.S. Groups' Foreign Income
Client Newsflash
March 6, 2009 Proposed Tax Legislation Affecting Hedge Funds
Client Newsflash
January 27, 2009 Proposed Relief for Cancellation of Debt Income
Client Newsflash
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