The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more
11/3/2016
/ Collateralized Debt Obligations ,
Corporate Counsel ,
Foreign Corporations ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Multinationals ,
Parent Corporation ,
Private Equity ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
S-Corporation ,
Section 385 ,
Stocks
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more
7/28/2015
/ Enterprise Risks ,
Fee Waivers ,
Internal Revenue Code (IRC) ,
Intra-Group Transactions ,
Investment Management ,
IRS ,
Management Fees ,
Proposed Regulation ,
Safe Harbors ,
Taxable Distributions ,
U.S. Treasury
Are you a day late? -
On March 5, the Internal Revenue Service (the IRS) published proposed regulations (REG-100400-14, RIN 1545-BM14) (the Proposed Regulations) that would place strict new guidelines on the “next-day...more