Practice Mobile Menu Trigger Overview Experience Team Insights Subscribe to insights January 8, 2015 Client Update IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that... December 11, 2014 Client Update United Kingdom’s “Google Tax” – Government Unveils Draft Rules The UK Government published this week details of a new 25% “diverted profits” tax, which aims to counter cross-border ... September 23, 2014 Client Update Treasury Issues Long-Awaited Anti-Inversion Guidance The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that... September 10, 2014 Client Update Schumer Releases Draft Anti-Inversion Bill A draft of the bill that is being considered by Senator Schumer (D-NY) to reduce some of the economic incentives for corpo... May 21, 2014 Client Update Proposed Legislation Would Significantly Limit Inversion Transactions As expected, Senator Carl Levin and thirteen other Democratic Senators yesterday introduced a bill that would significantl... January 17, 2014 Client Update New Regulations Expand Reach Of Anti-Inversion Ownership Rules The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “... December 9, 2013 Client Update New Proposed and Final Regulations Address Withholding on “Dividend Equivalents” Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends f... February 27, 2013 Client Update Investment Management Regulatory Update - February 2013 SEC Rules and Regulations SEC Issues Guidance on New Iran Disclosure Requirements SEC Extends No-Action Relief to Bro... January 15, 2013 Client Update Certain Severance Benefits Are Not Subject to FICA Payroll Taxation: Sixth Circuit Denies Petition for En Banc Rehearing of Its Holding in Quality Stores On January 4, 2013, the Sixth Circuit denied the U.S. government’s petition for en banc review of its September 2012 dec... April 1, 2012 Articles & Books Impact of FATCA on Foreign Funds The breadth and complexity of the FATCA requirements in the proposed regulations issued by the IRS and Treasury Department... Load More
January 8, 2015 Client Update IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that...
December 11, 2014 Client Update United Kingdom’s “Google Tax” – Government Unveils Draft Rules The UK Government published this week details of a new 25% “diverted profits” tax, which aims to counter cross-border ...
September 23, 2014 Client Update Treasury Issues Long-Awaited Anti-Inversion Guidance The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that...
September 10, 2014 Client Update Schumer Releases Draft Anti-Inversion Bill A draft of the bill that is being considered by Senator Schumer (D-NY) to reduce some of the economic incentives for corpo...
May 21, 2014 Client Update Proposed Legislation Would Significantly Limit Inversion Transactions As expected, Senator Carl Levin and thirteen other Democratic Senators yesterday introduced a bill that would significantl...
January 17, 2014 Client Update New Regulations Expand Reach Of Anti-Inversion Ownership Rules The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “...
December 9, 2013 Client Update New Proposed and Final Regulations Address Withholding on “Dividend Equivalents” Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends f...
February 27, 2013 Client Update Investment Management Regulatory Update - February 2013 SEC Rules and Regulations SEC Issues Guidance on New Iran Disclosure Requirements SEC Extends No-Action Relief to Bro...
January 15, 2013 Client Update Certain Severance Benefits Are Not Subject to FICA Payroll Taxation: Sixth Circuit Denies Petition for En Banc Rehearing of Its Holding in Quality Stores On January 4, 2013, the Sixth Circuit denied the U.S. government’s petition for en banc review of its September 2012 dec...
April 1, 2012 Articles & Books Impact of FATCA on Foreign Funds The breadth and complexity of the FATCA requirements in the proposed regulations issued by the IRS and Treasury Department...