Searching Content by Ethan Harris from Shearman & Sterling LLP ordered by Published Date Descending.
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Base Erosion And Anti-Abuse Tax (BEAT): Government Issues Proposed Regulations
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding the base erosion and anti-abuse tax (generally referred to as the "BEAT").
United States
20 Dec 2018
Regulations Proposed To Reduce Tax On Income Inclusions Under Section 956
On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations
United States
9 Nov 2018
IRS Announces Study Of Active Trade Or Business Requirement For Spin-Off Transactions
On September 25, 2018, the IRS announced that it is undertaking a study regarding the application of the five-year active trade or business requirement of Section 355(b) ...
United States
12 Oct 2018
Treasury And IRS Issue Final Regulations On Inversions
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the "Final Regulations").
United States
26 Jul 2018
Tax Court Rules Family Office Is Engaged In A Trade Or Business
On December 13, 2017, in Lender Management, LLC v. Commissioner, the U.S. Tax Court ruled that a family office, Lender Management, LLC ("Lender Management"), was "carrying on a trade or business"...
United States
15 Jan 2018
Trump Administration And Congressional Leaders Release Tax Reform Framework
On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the "Framework").
United States
5 Oct 2017
IRS Expands Scope Of Spin-Off Private Letter Rulings In 18-Month Pilot Program
On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the "Pilot Program Rev. Proc.") that it is expanding the scope of spin-off private letter ruling requests that it will consider.
United States
2 Oct 2017
One-Year Delay To The Application Of Section 385 Documentation Rules
The documentation rules would have originally applied to debt instruments issued or deemed to be issued on or after January 1, 2018.
United States
15 Aug 2017
Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings On Certain Spin-Off Debt Exchanges
The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation's transfer of stock or securities of a controlled corporation...
United States
18 May 2017
Update On US Federal Tax Reform Proposals
On April 26, the Trump Administration made its much-anticipated release of several "core principles" of its tax plan.
United States
5 May 2017
Highly-Anticipated Final Regulations On Related-Party Debt Instruments Issued
On October 13, 2016, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 385 of the Internal Revenue Code...
United States
22 Oct 2016
Spin-Off Revenue Procedure Removes A No-Rule Area And Provides Safe Harbors For Unwinding High Vote/Low Vote Stock Structures
One of the requirements for a tax-free spin-off under Section 355 is that the distributing corporation ("D") distributes stock of the controlled corporation ("C") representing "control" of C (the "Distribution of Control Requirement").
United States
27 Jul 2016
Treasury And IRS Issue New Spin-Off Proposed Treasury Regulations On Device And Active Trade Or Business Requirements
The Proposed Regulations contain substantive rules with respect to spin-off areas that Treasury and the IRS previously announced were under study and for which private letter rulings would not be issued.
United States
21 Jul 2016
Proposed Regulations On Related-Party Debt Instruments Would Result In Dramatic Adverse Tax Consequences
The broad scope of the Proposed Regulations also would impact common decisions primarily motivated by non-tax concerns, such as which company in an expanded group will borrow from third parties.
United States
9 Jun 2016
Treasury And IRS Issue Regulations On Inversions And Earnings Stripping
On April 4, 2016, the Treasury Department and the IRS issued temporary regulations under Section 7874 on inversion transactions that added some new restrictions and implemented provisions previewed in two prior IRS notices.
United States
20 Apr 2016
Treasury And IRS Issue Additional Anti-Inversion Notice
The Treasury Department and the IRS released Notice 2015-79 (the "2015 Notice") on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by them on September 22, 2014.
United States
27 Nov 2015
IRS Issues Final Regulations On F Reorganizations
In September 2015, the Treasury Department and the IRS issued final regulations (T.D. 9739) that provide guidance with respect to the qualification of a transaction as a reorganization under Section 368(a)(1)(F).
United States
21 Oct 2015
Spin-Off Revenue Procedure And Notice Announcing New No-Rule Areas That Are Under Study
On September 14th, the IRS released Rev. Proc. 2015-43 (the "Rev. Proc.") announcing new "no-rule" areas with respect to spin-offs involving substantial amounts of investment assets...
United States
24 Sep 2015
Treasury And IRS Issue Inversion Notice
The Treasury Department and the IRS released Notice 2014-52 on September 22nd to limit expatriation transactions.
United States
6 Oct 2014
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