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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 21, 2016 Final and Temporary Section 385 Regulations
October 14, 2016 Final and Temporary Section 385 Regulations
Client Memorandum
October 7, 2016 Tax Journal: UK Tax Issues or US Merger Agreements
July 29, 2016 Insuring M&A Tax Risk
Tax Journal
June 13, 2016 Partners as Employees? IRS Says Not So Fast
Client Memorandum
April 15, 2016 Discussion of Recent Anti-Inversion and Intercompany Debt Rules
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
August 7, 2014 Webcast – Corporate Inversions: Where we are and where we may be going
Webcast
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
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

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