Search
Searching Content indexed under Corporate/Commercial Law by Richard M Corn ordered by Published Date Descending.
Links to Result pages
 
1  
 
Title
Country
Organisation
Author
Date
1
Proposed Regulations On Built-In Gains And Losses Under Section 382(h)
On September 10, 2019, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury (the "Treasury")
United States
25 Sep 2019
2
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
3
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
4
Impact of Recent Tax Legislation On M&A Transactions
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the "Tax Act") that may affect M&A Transactions.
United States
12 Feb 2018
5
House Of Representatives Passes The Tax Cuts And Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison Of The Bill Passed By The House And The Modified Senate Bill
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10.
United States
21 Nov 2017
6
IRS Issues Guidance On "North-South" Transactions
The Ruling, under the facts set forth under Situation 1, spells out the paradigmatic case of a "north-south" transaction.
United States
17 May 2017
7
Tax Court Rules That Extensions Of Variable Prepaid Forward Contracts Do Not Result In Taxable Exchanges
Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical VPFC did not give rise to a taxable exchange to the obligor because a VPFC is solely an obligation...
United States
2 May 2017
8
Proposed Regulations Under Section 355 Clarify Device And Active Trade Or Business Requirements For Tax-Free Spin-offs
First, the proposed regulations clarify the "device" test and its relationship to the "business purpose" requirement.
United States
29 Jul 2016
9
Proposed Treasury Regulations Aim To Curb Elective Treatment Of M&A Transaction Costs
Some taxpayers have taken the position that an acquiring corporation and a target corporation, when the target corporation is joining the acquiring corporation's consolidated corporate group, can choose between taking certain acquisition-related expenses into account in the target's pre-acquisition taxable year or the post-acquisition consolidated taxable year.
United States
1 Apr 2015
Links to Result pages
 
1