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Capital Gains Tax
European Union
Cleary Gottlieb Steen & Hamilton LLP
On February 18, 2020, the ECOFIN group included the Cayman Islands in the EU's list of non-cooperative third country jurisdictions.
United States
Ostrow Reisin Berk & Abrams
Sole proprietorships and pass-through entity structures, which include partnerships, S corporations and certain limited liability companies (LLCs), ...
Proskauer Rose LLP
Creating a grantor retained annuity trust (commonly referred to as a "GRAT") is a relatively simple way to transfer property to your children at virtually no gift tax cost.
Cadwalader, Wickersham & Taft LLP
Treasury recently delivered two sets of proposed regulations to the Office of Management and Budget for review, bringing them closer to public release.
Ostrow Reisin Berk & Abrams
The internal rate of return (IRR) waterfall arrangement has gained popularity in recent years as a way to shift risk from equity investors,...
Bowditch & Dewey
The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program under section 1400Z of the Internal Revenue Code ("1400Z")
Smith Gambrell & Russell LLP
In an earlier article we posted entitled "What's in a Name? (Part 1)," we set forth the various possible ways that assets can be titled. Titling controls how an asset that you...
Pryor Cashman LLP
Through the lens of his extensive expertise in professional services malpractice, Partner James S. O'Brien, Jr. conducted an analysis ...
Cadwalader, Wickersham & Taft LLP
Across the real estate industry, "Opco/Propco" structures continue to be used as a method of raising debt against the real estate assets of a business.
Proskauer Rose LLP
On December 19, 2019, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued final regulations (the "Final Regulations") ...
Shearman & Sterling LLP
On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the "Final Regulations") regarding "Qualified Opportunity Zones"
Fenwick & West LLP
U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules,...
Steptoe & Johnson LLP
Section 1400Z-2, added by Public Law 115-97 (the Tax Cuts and Jobs Act), provides tax incentives for investors to make equity investments...
Lowndes, Drosdick, Doster, Kantor & Reed, P.A.
If you are considering making an opportunity zone investment, December 31, 2019 is the last day you can make your investment and receive the maximum tax benefit.
Dickinson Wright PLLC
A redemption of stock owned by a shareholder of a corporation may be characterized as a "sale or exchange" under IRC Section 302 or as a "dividend" payment under IRC Section 301.
Kutak Rock LLP
This has very important tax consequences.
Duane Morris LLP
On Friday, December 6th, the IRS/Treasury delivered to the White House's Office of Management and Budget (OMB)
DLA Piper
The Qualified Opportunity Zone Program (QOZ Program) was created by Congress as part of the Tax Cuts and Jobs Act of 2017.
The Treasury Department and the IRS recently issued Revenue Procedure 2019-38, providing a safe harbor under which certain rental estate activities will be treated as a trade or business solely
Ostrow Reisin Berk & Abrams
If you have established or plan to establish one or more trusts as part of your estate plan, be sure to evaluate the tax implications.
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