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Searching Content indexed under Corporate/Commercial Law by Bernie Pistillo 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
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
3
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
4
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
5
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
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