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.
September 17, 2020 Allocating Tax Risks in Private M&A Transactions: Non-Resident Capital Gains Tax

International Law Office

August 3, 2020 IRS Proposes Carried Interest Regulations
Client Alert
July 4, 2020 CARES Act: Relief for Nonprofit and Tax-Exempt Organizations – Updated
Client Memorandum
May 27, 2020 Proposed Regulations on Deductibility of Governmental Settlements
Client Memorandum
April 27, 2020 The CARES Act for Gig Workers and Others Who Work for Themselves
Client Memorandum
March 26, 2020 Tax Relief: Congress Passes CARES Act
Client Memorandum
March 21, 2020 IRS Expands Tax Day Relief
Client Alert
March 20, 2020 Rush Summary - Key Elements of Senate Republican Phase 3 Stimulus Proposal
Client Memorandum
March 19, 2020 Internal Revenue Service Permits Taxpayers to Defer Certain April 15th Tax Payments
Client Memoradum
March 18, 2020 Families First Coronavirus Response Act: Key Takeaways Regarding Paid Leave Benefits
Client Alert
February 11, 2020 The 16th Amendment, a National Wealth Tax, and More

Tax Notes

January 20, 2020 The Objectivity of the Reasonable Basis Defense to Tax Penalties

Tax Analysts – Tax Notes Federal

September 13, 2019 Proposed Changes on Loss Carryforwards Are a (R)BIG Deal for M&A
Client Memorandum
October 25, 2018 Holding Shares Through Partnerships: Some Observations

Tax Journal, October 5, 2018

 

February 2, 2018 Tax Themes in Acquisition Financing

Tax Journal, February 2, 2018

January 5, 2018 TCJA Navigator
Client Memorandum
December 20, 2017 Davis Polk Previews the New Tax Regime
Client Memorandum
December 5, 2017 Senate Tax Bill Navigator
Client Memorandum
December 4, 2017 Last Minute Retention of Corporate AMT in Senate Tax Bill has Unintended Consequences
November 16, 2017 House Tax Bill Navigator
Client Memorandum
November 8, 2017 Tax Reform Proposal - Uncertainty for Year-End Compensation Planning: What You Can Do to Prepare
Client Memorandum
October 2, 2017 Court Invalidates Anti-Inversion Regulation
Client Memorandum
September 25, 2017 So You Want to Buy a Stake in a Private Equity Manager?
Client Memorandum
September 6, 2017 Recent Developments for Sections 409A and 457: Proposed Regulations and Chief Counsel Memorandum
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
November 2, 2016 NYC Bar Association, Committee on Estate and Gift Taxation
Report on the Section 2704 Proposed Regulations
October 14, 2016 Final and Temporary Section 385 Regulations
Client Memorandum
October 7, 2016 Tax Journal: UK Tax Issues on US Merger Agreements
June 13, 2016 Partners as Employees? IRS Says Not So Fast
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
October 28, 2015 Closing Your M&A Deal on a Weekend
Client Memorandum
July 1, 2015 Recent Compensation-Related Tax Developments
Client Memorandum
June 12, 2015 Amazon Branches Out
Views on Recent Developments in Tax
April 3, 2015 IRS Releases Final Regulations Under Section 162(m): Some Relief for Newly Public Companies
Client Memorandum
January 8, 2015 IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States
Client Memorandum
December 11, 2014 United Kingdom’s “Google Tax” – Government Unveils Draft Rules
Client Memorandum
September 23, 2014 Treasury Issues Long-Awaited Anti-Inversion Guidance
Client Memorandum
September 10, 2014 Schumer Releases Draft Anti-Inversion Bill
Client Memorandum
May 21, 2014 Proposed Legislation Would Significantly Limit Inversion Transactions
Client Newsflash
March 14, 2014 U.K. Companies Listing in the U.S.
Tax Journal
January 17, 2014 New Regulations Expand Reach Of Anti-Inversion Ownership Rules
Client Newsflash
 
December 9, 2013 New Proposed and Final Regulations Address Withholding on “Dividend Equivalents”
Client Memorandum
February 27, 2013 Investment Management Regulatory Update
Client Newsletter
January 15, 2013 Certain Severance Benefits Are Not Subject to FICA Payroll Taxation: Sixth Circuit Denies Petition for En Banc Rehearing of Its Holding in Quality Stores
Client Memorandum
April 1, 2012 Impact of FATCA on Foreign Funds
Practical Law The Journal
March 7, 2012 Summary of the Proposed FATCA Regulations
Client Memorandum
February 8, 2012 Treasury Issues Proposed FATCA Regulations, Seeks to Respond to Market Concerns
Client Memorandum
January 20, 2012 New Regulations Address Withholding on “Dividend Equivalents”
Client Newsflash

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