News & Analysis as of

Fair Market Value New Guidance

Latham & Watkins LLP

French Tax Authorities’ Guidelines Clarify the New Legal Framework Applicable to Management Package Instruments

Latham & Watkins LLP on

The regime sets new rules regarding the taxation of gains realized on the sale of securities held by employees or executives in the frame of management packages....more

Kaufman & Canoles

ESOPs, Benefits & Compensation Client Alert - January 2025

Kaufman & Canoles on

On January 16, the Department of Labor released long-awaited guidance on how to determine the value of employer stock in purchase and sale transactions involving an ESOP. Unfortunately for those in the ESOP community hoping...more

Chambliss, Bahner & Stophel, P.C.

Client Update – New OIG General Compliance Guidance Released

November 28, 2023 | Legal Update On November 10, 2023, the Office of the Inspector General (OIG) released its widely anticipated General Compliance Program Guidance (GCPG). The OIG had previously announced that it would...more

McDermott Will & Schulte

IRS Guidance Declares That Taxpayers Must Include Staking Rewards in Gross Income

On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which concludes that the fair market value of staking rewards received by a cash-method taxpayer is includible in the taxpayer’s gross...more

Proskauer - Tax Talks

IRS and Treasury Provide Guidance on the Excise Tax on Repurchases of Corporate Stock under Section 4501

Proskauer - Tax Talks on

On December 27, 2022, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) released Notice 2023-2 (the “Notice”), which provides guidance regarding the application of the 1% excise tax...more

King & Spalding

SBA Change in Ownership Approval Guidance

King & Spalding on

SBA Releases Guidance Addressing Corporate Mergers and Acquisitions in the Context of Paycheck Protection Program Loans - Many clients have been asking about the impact of a Paycheck Protection Program (PPP) Loan and the...more

Chambliss, Bahner & Stophel, P.C.

SBA Issues Key Guidance on Change of Ownership for PPP Loan Recipients

The Small Business Administration (SBA) recently issued a Procedural Notice (the Notice) containing details about the required procedure that Paycheck Protection Program borrowers (PPP borrowers) must follow when engaging in...more

Foley & Lardner LLP

SBA Guidance on Changes in Ownership of PPP Loan Borrowers

Foley & Lardner LLP on

On Friday, October 2, 2020, the Small Business Administration (“SBA”) issued a Procedural Notice (the “Notice”) providing guidance on the notification and consent requirements for changes in ownership of borrowers of...more

Pillsbury Winthrop Shaw Pittman LLP

Paycheck Protection Program Update: New SBA Guidance Impacting M&A Activity

The Small Business Administration’s latest guidance tells PPP lenders under what conditions they may approve changes of ownership involving PPP borrowers. Standard PPP loan paperwork has required PPP borrowers to seek...more

Seyfarth Shaw LLP

CMS’ Proposed Stark Rule Change and Guidance on “The Big Three”: Fair Market Value, Commercial Reasonableness, and Taking Into...

Seyfarth Shaw LLP on

As part of a larger “Regulatory Sprint to Coordinated Care” the Centers for Medicare & Medicaid Services (CMS) of the U.S. Department of Health & Human Services (HHS) recently issued a proposed rule aimed at modernizing and...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Guidance Regarding Virtual Currency Transactions

On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more

Proskauer - Tax Talks

IRS answers some, but not all, questions in long-awaited cryptocurrency guidance

Proskauer - Tax Talks on

The first official guidance on the taxation of cryptocurrency transactions in more than five years has been issued. The guidance includes both a Revenue Ruling (Rev. Rul. 2019-24, 2019-44 I.R.B. 1) and answers to...more

Proskauer - Tax Talks

LIBOR Transition: U.S. Tax Guidance From the IRS

Proskauer - Tax Talks on

The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the...more

A&O Shearman

IRS Issues Virtual Currency Tax Guidance on Forks and Airdrops

A&O Shearman on

On October 9, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Ruling 2019-24 (the “Revenue Ruling”) and questions and answers (the “Q&A” and, together with the Revenue Ruling, the “Guidance”) addressing certain...more

Fenwick & West LLP

IRS Issues Long-Awaited Cryptocurrency Guidance in Revenue Ruling 2019-24 and New FAQs

Fenwick & West LLP on

On October 9, 2019, the IRS released Revenue Ruling 2019-24, which provides guidance with respect to hard forks and airdrops of cryptocurrency, and new frequently asked questions (FAQs), which provide guidance on other...more

Sullivan & Worcester

Am I Out-of-Bounds?

Sullivan & Worcester on

Every golfer knows there is a penalty attendant to hitting the ball out-of-bounds. In business, as with golf, being "out-of-bounds" when dealing with the Internal Revenue Code has penal consequences too. But there the analogy...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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