News & Analysis as of

Corporate Restructuring Corporate Taxes

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

DLA Piper

Chile: Servicio de Impuestos Internos publica instrucciones sobre facultad de tasación y su aplicación a reorganizaciones...

DLA Piper on

El Servicio de Impuestos Internos (SII) dictó la Circular N°23 que imparte instrucciones sobre el nuevo texto del artículo 64 del Código Tributario. A modo de contexto, el SII tiene una facultad legal para tasar el precio o...more

Frost Brown Todd

Advanced Section 1202 (QSBS) Planning for S Corporations - UPDATED March 2025

Frost Brown Todd on

Section 1202 provides for a substantial exclusion of gain from federal income taxes when stockholders sell qualified small business stock (QSBS). But a number of requirements must be met before a stockholder is eligible to...more

Barnea Jaffa Lande & Co.

Knesset Committee Approves Bill Easing Tax Relief in Restructuring

The Knesset Finance Committee approved a draft bill for second and third readings to ease the conditions for tax relief during corporate restructuring. The bill was first published in the initial draft bill within the tax...more

Orrick, Herrington & Sutcliffe LLP

Italy Founder Series: The Delaware Flip. A Bridge for Italian Startups to the U.S. Market

The United States represents a flourishing capital market and an advanced technological ecosystem, making it an attractive destination for startups worldwide. For European startups, particularly Italian ones, though,...more

Conyers

Top 5 British Virgin Islands Publications of 2024

Conyers on

Our British Virgin Islands office’s most popular publications provided valuable insights on doing business in the jurisdiction, effective asset recovery tools, strategies for addressing modern legal challenges, corporate...more

Conyers

Top 5 Bermuda Publications of 2024

Conyers on

In Bermuda, our most popular posts and publications provided updates from our Corporate practice, particularly regulatory changes and insurance insights, along with reflections on private client matters and litigation....more

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

Latham & Watkins LLP on

Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

Nutter McClennen & Fish LLP

M&A in Brief: Q4 2022

Headlines - - Tax Issues for F Reorganizations in M&A Transactions - Presidential Executive Order Places Heightened Importance on National Security Risks and Committee on Foreign Investments in the United States...more

Barnea Jaffa Lande & Co.

District Court: Changing a Business Model after Purchasing Company Shares Does not Always Constitute a Tax Event

In May 2022, the Tel Aviv District Court issued an important ruling in the Medingo Ltd case on the tax aspects of business restructuring. This ruling joins a series of previous rulings, in the Gteko case and the Broadcom...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

White & Case LLP on

The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Coronavirus/COVID-19 Update #2

The question is no longer whether the volatility created by the COVID-19 pandemic will deepen the difficulties businesses and other institutions face in the coming months, but by how much and in what ways. In the past few...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Latham & Watkins LLP

Corporate Reorganisations 2019

Latham & Watkins LLP on

‘Corporate reorganisation’ is something of an umbrella term, and is used in many different contexts to mean a multitude of different things. At one extreme, a reorganisation may refer to ‘paper’ changes to a corporate group’s...more

A&O Shearman

Taxation of Restructuring Profits in Germany - Tax Administration and Legislator Swiftly React to a Recent Detrimental Decision of...

A&O Shearman on

A recent decision by the German Federal Fiscal Court (BFH) has caused significant concerns in the restructuring community because it will severely complicate future restructurings in Germany or even make them impossible...more

Eversheds Sutherland (US) LLP

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

Latham & Watkins LLP

Update: Upheaval in the German Restructuring Market: Need-to-Know Facts, Alternative Tools and New Draft Law

Latham & Watkins LLP on

To date, a debt waiver has been frequently used as a tool to successfully restructure German-based companies in financial difficulties. A decision of the German Federal Fiscal Court (Bundesfinanzhof) published on...more

McDermott Will & Emery

New IRS Rulings Should Provide Greater Certainty for Corporate Restructurings

McDermott Will & Emery on

On May 5, 2015, the Internal Revenue Service (IRS) issued two long-awaited rulings, Rev. Rul. 2015-09 and Rev. Rul. 2015-10, that should ease the lives of corporate tax planners. Each ruling addressed an increasingly common...more

Latham & Watkins LLP

IRS Rulings Clarify Tax Treatment of Multi-Tier Restructuring Transactions

Latham & Watkins LLP on

By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques. A pair of revenue rulings the US Internal Revenue Service (IRS)...more

Blake, Cassels & Graydon LLP

Doing Business in Canada

This Guide provides non-Canadians with an introduction to the laws and regulations that affect the conduct of business in Canada and, in particular, in the province of Ontario. In some cases, this Guide also identifies issues...more

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