Searching Content by Shawn R. O’Brien from Mayer Brown ordered by Published Date Descending.
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Sharpened Knives: US Internal Revenue Service Continues Slicing Through Barrier Options With CCA 201547004
The efforts of the US Internal Revenue Service (the "IRS") to broadly challenge the purported federal income tax consequences of barrier and basket options has been gathering steam over the past few years.
United States
25 Nov 2015
Out-Of-The-Money: The IRS Designates Basket Options As Listed
It's been a long hard road for barrier options.
United States
20 Jul 2015
US IRS Issues Proposed Regulations On Master Limited Partnership Income
The US Internal Revenue Service (IRS) has published proposed regulations clarifying which activities generate "qualifying income" for a Master Limited Partnership (MLP).
United States
8 May 2015
Significant Progress Made On The OECD’s BEPS Action Plan
This Legal Update is the second in a series that Mayer Brown Tax lawyers are publishing on key developments at the national and international levels related to the Organisation for Economic Co-Operation and Development’s ("OECD") Action Plan on Base Erosion and Profit Shifting (the "BEPS Action Plan").
10 Mar 2014
Income From Providing Hydraulic Fracturing Services Is "Qualifying Income" For Master Limited Partnerships
A Master Limited Partnership or MLP (sometimes called a publicly traded partnership or PTP), is an attractive business entity because it is treated as a partnership for federal income tax purposes even though the ownership interests in the MLP are publicly traded.
United States
29 Oct 2013
The OECD’s Action Plan On Base Erosion And Profit Shifting
The Organisation for EconomicCoordination and Development released its highly anticipated Action Plan on Base Erosion and Profit Shifting, which was then unanimously approved by the G-20 Finance Ministers at their July 20, 2013 meeting in Moscow.
United States
1 Aug 2013
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