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.
December 21, 2011 Key Elements of the Revised Model Credit Agreement Provisions
ABA Commercial Law Newsletter, Winter 2011
November 3, 2011 Proposed Treasury Regulations Clarify U.S. Taxation of Investments by Foreign Governments
Client Newsflash
September 29, 2010 NYSBA Tax Section Letter 1221
Report on Medicare Contribution Tax Definition of Net Investment Income
July 23, 2010 Tax Court Rules on Variable Prepaid Forwards and Stock Lendings
Client Memorandum
July 9, 2010 Davis Polk Regulatory Implementation Slides
Client Memorandum
July 9, 2010 Summary of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Passed by the House of Representatives on June 30, 2010
Client Memorandum
May 28, 2010 House Targets International and Domestic Tax Planning Strategies
Client Memorandum
May 21, 2010 Update on "Carried Interest" Legislation
Client Newsflash
May 1, 2010 Structuring Hedge Fund Manager Compensation: Tax and Economic Considerations
The Journal of Taxation, Vol. 112, No. 5
March 22, 2010 Capital Ideas: The Taxation of Derivative Gains and Losses
Tax Notes
March 19, 2010 HIRE Act Codifies FATCA Rules, Ban on Bearer Bonds and Rules for Withholding on “Dividend Equivalents”
Client Memorandum
March 11, 2010 New “PROP Trading Act” Would Expand “Volcker” Prohibitions
Client Memorandum
March 3, 2010 Delaware Court Upholds Use of 4.99% Poison Pill to Protect NOLs
Client Memorandum
February 26, 2010 Proposed FBAR Regulations Address Some Concerns but Leave Many Questions Unanswered
Client Newsflash
February 26, 2010 IRS Suspends, Waives Certain FBAR Filings
Client Newsflash
February 22, 2010 NYSBA Tax Section Report No. 1205
Report Commenting on 2010-2011 New York State Executive Budget
January 15, 2010 President Obama Proposes Tax on Large Financial Firms
Client Newsflash
December 9, 2009 House to Consider Bill Containing Carried Interest Proposal, Ban on Bearer Bonds and Updated FATCA Rules
Client Memorandum
October 28, 2009 Highlights of Proposed Legislation Aimed at Combating Offshore Tax Evasion
Client Memorandum
September 23, 2009 IRS Releases Internal Memorandum Regarding Lending in the United States by Foreign Persons
Client Newsflash
August 17, 2009 Obama Administration Proposes Sweeping Legislation to Regulate Over-The-Counter Derivatives
Client Newsflash
August 7, 2009 Extension of FBAR Filing Deadline to June 30, 2010 for Certain Persons
Client Newsflash
June 24, 2009 Extension of FBAR Filing Deadline for Certain Offshore Investments
Client Memorandum
June 1, 2009 Derivatives Provisions in the American Clean Energy and Security Act of 2009
Client Memorandum
May 12, 2009 Highlights of the Administration's 2010 Revenue Proposals
Client Memorandum
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
February 13, 2009 Select Tax Provisions in the American Recovery and Reinvestment Act of 2009
Client Newsflash
January 27, 2009 Proposed Relief for Cancellation of Debt Income
Client Newsflash
December 17, 2008 New York State Proposes to Tax Carried Interest Earned by Non-resident Partners
Client Newsflash
October 31, 2008 IRS Announces Notice of Proposed Rulemaking Relating to U.S. Taxation of Foreign Investors in Certain Infrastructure Investments
Client Newsflash
October 23, 2008 Deferred Compensation Rules May Affect US Employees of Foreign Corporations, Including Foreign Subsidiaries of US Corporations
Client Memorandum
October 22, 2008 Section 457A
Client Memorandum
February 26, 2008 IRS Gives Relief on Application of New 162(m) Performance-Based Compensation Rules
Client Newsflash
January 31, 2008 IRS Ruling Reflects Changed Position On Application of $1 M Deduction Limit on Annual Compensation to Top Executives Under Internal Revenue Code Section 162(m)
Client Newsflash
March 4, 2007 Equity, Debt, NOT – The Tax Treatment of Non-Debt Open Transactions
60 Tax Lawyer No. 3, 653-684 (Spring 2007)
March 4, 2002 Dirty Linen: Airing Out the Wash Sale Rules
3 Journal of Taxation of Financial Products, No. 3, page 41 (Summer 2002)
January 1, 1985 The Importance of Considering Liabilities in Tax Transitions
98 Harv. L. Rev. 1842

Pages

Insights Search: