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Pillsbury Winthrop Shaw Pittman LLP

Vindication: The U.S. Tax Court Sustains IRS Position on Basket Options in GWA, LLC

Pillsbury Winthrop Shaw Pittman LLP on

In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more

Cadwalader, Wickersham & Taft LLP

Keep Your Eyes on Mark-to-Market

Cadwalader, Wickersham & Taft LLP on

We report elsewhere in this issue on Senate Finance Committee Chair Ron Wyden's (D-Ore.) proposed mark-to-market tax on billionaires. On August 5, 2021, Wyden also introduced the Modernization of Derivatives Tax Act of 2021...more

Robins Kaplan LLP

Financial Daily Dose 1.6.2020 | Top Story: Oil Futures Jump as Concerns Deepen Over Mideast Volatility

Robins Kaplan LLP on

Oil jumped for a second straight day, with futures near $70/barrel as fallout from the U.S.’s drone-strike assassination of Iran’s Qassem Soleimani continues to raise “the prospect of disruptions in the world’s most important...more

Troutman Pepper Locke

Private Equity and Hedge Fund Managers Take Caution - Proposed Treasury Regulations Threaten Management Fee Waivers

Troutman Pepper Locke on

On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more

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