Searching Content by Peter Connors from Orrick ordered by Published Date Descending.
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HMRC's New Approach To Cryptoassets – Tax First, Define Later
The UK tax authority, Her Majesty's Revenue & Customs (HMRC), has taken a further step towards tackling perceived tax avoidance in transactions involving cryptoassets.
United States
2 Oct 2019
Carbon Capture Sequestration – Orrick Responds To The IRS Request For Comments
On May 2, 2019, the Internal Revenue Service ( the "IRS") released Notice 2019-32 (the "Notice") which requested comments for Carbon Oxide Sequestration Section 45Q of the Internal Revenue Code
United States
20 Aug 2019
New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations In Altera Case
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7...
United States
1 Jul 2019
Proposed Regulations Favorably Affect Foreign Currency Hedging Transactions
United States shareholders of controlled foreign corporations ("CFCs") are required to include certain forms of passive income in their taxable income.
United States
14 Jun 2019
IRS Reports Record $312 Million In Whistleblower Bounties
In February, the Internal Revenue Service (IRS) released its FY 2018 Annual Report and announced a record-breaking year for the agency's whistleblower program.
United States
28 Mar 2019
Ninth Circuit Withdraws Controversial Altera Opinion And Will Allow New Judge To Make Ultimate Determination
On August 7, 2018, the Ninth Circuit withdrew its July 24 decision in Altera so that new panel member, Judge Susan P. Graber, can now consider the case.
United States
16 Aug 2018
IRS Reverses Its Position Regarding The Treatment Of Merger Breakup Fees
In July 2014 AbbVie Inc. and Shire Plc announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence...
United States
16 Mar 2017
The Final §385 Regulations (Part II) - Classifying Interests In A Corporation
On October 13, 2016, the Treasury Department issued much anticipated regulations under Internal Revenue Code §385. These regulations, which consist of both temporary and final regulations...
United States
27 Feb 2017
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...
United States
14 Feb 2017
IRS Releases Transition Guidance For The Dividend Equivalent Rules
On December 2, 2016, the Internal Revenue Service (the "IRS") issued Notice 2016-76 (the "Notice"), which provides highly anticipated guidance regarding "dividend equivalent" payments...
United States
20 Dec 2016
IRS And Treasury Issue Final Regulations Under §385 Classifying Interests In A Corporation
On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the "Final" or "Temporary" Regulations) under Internal Revenue Code section 385.
United States
16 Nov 2016
Tax Benefit From Leveraged Partnerships Shut Down By New IRS Regulations
The IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged partnerships.
United States
17 Oct 2016
Proposed Regulations Under §385 Classifying Interests In A Corporation
Orrick attorneys authored an article, titled "Proposed Regulations Under §385 Classifying Interests in a Corporation," addressing Section 385 regulations proposed by the Internal Revenue Service and the U.S. Treasury Department...
United States
1 Aug 2016
IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments As Equity
On April 4, 2016, the IRS and U.S. Treasury Department issued proposed Treasury Regulations designed to curb the ability of large multinational companies to reduce their U.S. taxable income...
United States
5 May 2016
100% QSBS Exclusion Soon To Be Made Permanent
The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain...
United States
30 Dec 2015
IRS Announces Intent To Tax Transfers To Partnerships
Generally, Code section 721(a) provides that a transfer of property to a partnership in exchange for an interest in the partnership will be accorded non-recognition treatment.
United States
18 Aug 2015
IRS Proposes To Revise The Treatment Of Nonperiodic Payments
While the Regulations are designed to resolve issues, many unanswered questions remain.
United States
17 Jun 2015
New Treasury Regulations Target Corporate Inversions
The IRS and Treasury Department announced a number of new regulations intended to make it more difficult to qualify for tax advantages associated with inversion transactions.
United States
13 Oct 2014
IRS Scripts A New Tune With Final Whistleblowing Regulations
Section 7623 of the Internal Revenue Code authorizes the Treasury Secretary to pay an award as he deems necessary for detecting underpayments of tax.
United States
12 Sep 2014
New York State Corporate Tax Law Reform: The Impact On Companies Providing Digital Products
On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime.
United States
6 Aug 2014
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