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Internal Revenue Service › Securities Transactions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Pillsbury Winthrop Shaw Pittman LLP

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

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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

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

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In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Cadwalader, Wickersham & Taft LLP

Crossing the U.S. Trade or Business Line

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YA Global Investments, LP (“YA Global”), a foreign investment fund that provided funding to portfolio companies in exchange for stock, convertible debentures, promissory notes and warrants, engaged U.S.-based Yorkville...more

Cadwalader, Wickersham & Taft LLP

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

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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

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

White & Case LLP on

On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Best Best & Krieger LLP

Best in Law: Take Some Time with Your Minute Book

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BB&K Business Attorney Brian Reider Discusses the Importance of Minute Books in the Southern California Newspaper Group - Looking back at the year, one recurring theme emerges with corporate clients and their...more

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