Searching Content indexed under Income Tax by Jason Bazar ordered by Published Date Descending.
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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'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 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
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
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