News & Analysis as of

Internal Revenue Code (IRC) Stocks Publicly-Traded Companies

Hogan Lovells

IRS reduces barriers to redomiciliations

Hogan Lovells on

On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more

Patterson Belknap Webb & Tyler LLP

QSBS Rollovers

Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS).  Less well known is Section 1202's cousin, Section 1045, which...more

Cadwalader, Wickersham & Taft LLP

IRS Takes Partnership Entity-Level View on FIRPTA’s Publicly Traded Stock Exception

The IRS has finally taken a view on the exception to FIRPTA (the Foreign Investment in Real Property Tax Act) for publicly traded stock of a United States real property holding corporation (a “USRPHC”) that is held by a...more

Proskauer Rose LLP

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer Rose LLP on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more

4 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide