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Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
Capital Markets Tax Quarterly
Welcome to Mayer Brown's Capital Markets Tax Quarterly (CMTQ). This is a new publication for Mayer Brown's Tax practice, so let us explain what we're about.
United States
23 Oct 2018
Tax Reform Income Acceleration Provision Inapplicable To Accrued Market Discount
On September 27, 2018, the US Internal Revenue Service (the "IRS") released Notice 2018-80 (the "Notice")
United States
4 Oct 2018
Redemption Of Interest In US Partnership Not Taxable To Foreign Investor; Tax Court Refuses To Follow Revenue Ruling 91-32
In general, a non-US person is not subject to US federal income tax when he sells stock of a US corporation.
United States
31 Jul 2017
Treasury And The IRS Introduce Significant Changes In The Final Section 385 Regulations On Intercompany Debt
This legal update provides a brief summary of the most significant changes included in the Final Regulations.
United States
17 Oct 2016
Treasury's New Anti-Inversion Regulations: Do They Go Too Far?
On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping.
United States
11 Apr 2016
The IRS And Treasury Issue New Anti-Inversion Notice
On November 19, 2015, the US Internal Revenue Service and the Treasury Department issued Notice 2015-79, announcing their intention to expand on previously issued guidance concerning inversions and post-inversion transactions.
United States
2 Dec 2015
Proposed US Treasury Regulations Attempt to Distinguish "Active" Insurance Companies from Hedge Funds
Offshore insurance companies can provide substantial tax benefits to their owner-insureds through current deductions for the insurance premium and, if properly structured, deferral on reserve investments.
United States
28 Apr 2015
Three Things US Audit Committee Members Should Consider In 2015
Audit Committees are facing increased demands from many quarters heading into 2015.
United States
26 Jan 2015
The IRS And Treasury Issue New Anti-Inversion Guidance
Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service ("IRS") and the Treasury Department ("Treasury") released Notice 2014-52 ("Notice") on September 22, 2014, describing new regulations to be issued by the government to curtail inversion transactions.
United States
26 Sep 2014
IRS And Treasury Issue Long-Awaited Guidance On Corporate Inversions And "Disqualified Stock"
On January 16, 2014, the Internal Revenue Service (the "IRS") and the Treasury Department (the "Treasury") issued longawaited temporary and proposed regulations under Code section 78741 relating to corporate inversions (the "Regulations").
United States
30 Jan 2014
Net Asset Value Credit Facilities
As real estate, buyout, infrastructure, debt, secondary, energy and other closed-end funds mature beyond their investment or commitment periods, they have often called and deployed the majority of their uncalled capital commitments on the acquisition of their investment portfolio.
United States
13 Aug 2013
Addressing UBTI Concerns In Capital Call Subscription Credit Facilities
A subscription credit facility (a Facility), also frequently referred to as a capital call facility, is a loan by a bank or other credit institution (the Creditor) to a real estate or private equity fund (the Fund).
United States
14 Nov 2012
New York State Seeks to Recharacterize a Nonresident Partnerís "Carried" Interest
In an effort to balance the New York State budget, Governor Paterson is supporting a proposal to amend the stateís tax law with respect to the treatment of carried interest income of nonresident fund managers from an investment fund located in New York as income for the performance of services, rather than investment income.
United States
8 Jul 2010
2009 Economic Stimulus Package: Certain Debt Repurchases by Businesses Granted Relief from Tax on Cancellation of Indebtedneses Income
The economic stimulus package, signed into law on February 17, 2009, grants corporations and businesses that repurchase their debt at a discount a right, under certain circumstances, to elect to defer the recognition of their cancellation of indebtedness (COD) income for up to five years.
United States
24 Feb 2009
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