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Searching Content by Bernie Pistillo from Morrison & Foerster LLP ordered by Published Date Descending.
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New Section 956 Regulations Expand Scope Of The New Participation Exemption But May Expose Borrowers To Increased Collateral Requirements
On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the "Code")...
United States
14 Nov 2018
2
Trump Administration Officials And Congressional Leaders Release "Unified Framework" For Tax Reform
Similar to a one-page plan previously released by the Trump administration back in April, the Framework sets forth a sweeping set of potential tax reform objectives but is lacking in substantive detail.
United States
5 Oct 2017
3
IRS Issues Final Debt-Equity Regulations
The Proposed Regulations have been the subject of significant controversy and provoked an outcry from practitioners, congressional hearings, and over 29,600 comments.
United States
4 Nov 2016
4
Latest Treasury Action On Inversions Upends Pending Transactions And Surprises Many For Its Broad Scope And Use Of Questionable Authority
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions
United States
27 Apr 2016
5
Proposed IRS Debt-Equity Regulations: Aimed At Post-Inversion "Earnings Stripping," But May Also Impact Ordinary Related-Party Debt
On April 4th, the IRS issued proposed regulations under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax purposes.
United States
18 Apr 2016
6
Recent Changes Make Permanent The 100% Exclusion Of Eligible Gain From Sales Of Section 1202 "Qualified Small Business Stock"
The Protecting Americans from Tax Hikes Act of 2015 (the "PATH Act") has amended Section 1202 of the Code to permanently extend the 100% exclusion for eligible gain on sales of qualified small business stock ("QSBS").
United States
18 Mar 2016
7
Private Ruling Endorses Taxpayer-Friendly Reading Of "Qualified Small Business" Under Section 1202
The IRS found that a company providing products and services primarily within the pharmaceutical industry was a "qualified trade or business" for purposes of Section 1202(e)(3).
United States
23 Sep 2014
8
The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?
The media have been abuzz with reports on the latest so-called "inversion" transactions shifting a U.S.-based multinational corporation’s tax residence offshore.
United States
28 Jul 2014
9
Recently Proposed Treasury Regulations Regarding The Allocation Of Partnership Recourse And Nonrecourse Liabilities Contain Significant Changes For Many Routine Partnership Transactions
On January 29, 2014, the Internal Revenue Service and the Treasury Department issued proposed regulations modifying the rules under Section 752 regarding the allocation of recourse and nonrecourse partnership liabilities and clarifying some aspects of the disguised sale rules of Section 707.
United States
17 Feb 2014
10
Managing Offshore Holding Companies From China: Recent Case May Suggest Increased Tax Risk
As our readers know, foreign investments into the People’s Republic of China ("PRC") are typically structured through one or more holding companies domiciled in offshore jurisdictions.
China
4 Nov 2013
11
Favorable New Guidance On Eligibility Of Wind And Other Renewable Energy Facilities For The PTC Or The ITC In Notice 2013-60
On September 20, 2013, the Internal Revenue Service released Notice 2013-60, which significantly clarifies and expands the eligibility rules applicable to the investment tax credit and production tax credit for wind and certain2 other renewable energy facilities.
United States
30 Sep 2013
12
Recent Changes Allow Tax-Free Receipt Of Up To $10 Million In Gain From The Sale Of Small Business Stock
Taxpayers who purchased QSBS in September 2010 or later will not be eligible to realize the benefit of the 100% gain exclusion until September 2015 at the earliest.
United States
24 Jan 2013
13
A Year-End Rush for the Exit? Tax Uncertainty and Transactional Planning in Q3/Q4 2012
A combination of pending actual and potential tax increases effective in 2013 may have a significant impact on transactional planning in the third and fourth quarters of 2012.
United States
15 Aug 2012
14
2011 Report Of Foreign Bank And Financial Accounts ("FBAR") Due June 30
We wanted to remind our clients that Treasury Form TD F-90 22.1 "Report of Foreign Bank and Financial Accounts" (commonly known as the "FBAR") is due on June 30, 2012 with respect to the calendar year 2011.
United States
20 Jun 2012
15
Reasserting Its Role As Final Interpreter Of The Law, The Supreme Court Rejects IRS "Fighting Regulation" In United States v. Home Concrete & Supply, LLC, Et Al.
On April 25, 2012, the Supreme Court issued a 5-4 opinion, written by Justice Breyer, concluding that Treasury Regulation § 301.6501(e)-1(a)(iii) was invalid.
United States
8 May 2012
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