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Internal Revenue Code (IRC) Financial Markets Internal Revenue Service

Pillsbury Winthrop Shaw Pittman LLP

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

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

Orrick, Herrington & Sutcliffe LLP

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...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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