Searching Content indexed under Corporate/Commercial Law by Ethan Harris 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
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
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
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 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
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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