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Searching Content indexed under Tax by Shearman & Sterling LLP ordered by Published Date Descending.
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1
Tax Guidance On The Transition From Interbank Offered Rates Under OIRA Review
On August 28, 2019, the U.S. Department of Treasury submitted proposed regulations on the tax consequences related to the phased elimination of interbank offered rates (the "Proposed Regulations")
United States
4 Sep 2019
2
The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems
In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules:
European Union
26 Aug 2019
3
Accounting Directive: European Parliament Resolution On Proposed Country-By-Country Tax Reporting Directive
On 27 March 2019, the European Parliament resolved to adopt, with amendments, the Commission's proposal for a directive to amend the Accounting Directive (2013/34/EU) as regards disclosure of income tax information
European Union
25 Jul 2019
4
Ninth Circuit Redo In Altera Upholds Treasury Regulation On Stock-Based Compensation
On June 7, 2019, in Altera Corp. v. Commissioner[1], a reconstituted panel of the U.S. Court of Appeals for the Ninth Circuit issued a new opinion upholding the validity of a Treasury Department
United States
3 Jul 2019
5
Final GILTI Regulations And Proposed Regulations On Subpart F Income And GILTI Bring Relief To Private Equity And Other Non-Corporate Investors
On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19)
United States
3 Jul 2019
6
Estate Planning Advisory
As a general rule, it is advisable to revisit your estate plan every few years, or if some major change occurs in your personal circumstances or in applicable law. Recent historic changes to the tax law warrant revisiting your estate plan now.
United States
10 Jun 2019
7
Opportunity Zones: Second Set Of Proposed Regulations Provide Clarity
On Wednesday, April 17, 2019, the Treasury Department and the Internal Revenue Service issued a broad, investment-friendly second set of Proposed Regulations (the "Proposed Regulations")
United States
7 May 2019
8
IRS Guidance On Taxation Of Professional Team Trades
The Internal Revenue Service ("IRS") issued Revenue Procedure 2019-18 that provides a safe harbor provision for professional sports teams that allows a team to treat the value of a traded player,
United States
30 Apr 2019
9
Base Erosion And Anti-Abuse Tax (BEAT): Government Issues Proposed Regulations
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding the base erosion and anti-abuse tax (generally referred to as the "BEAT").
United States
20 Dec 2018
10
Government Issues Proposed Regulations On Business Interest Expense Deduction Limitation: Overview And Impact On Leveraged Finance Market
On November 26, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated regulations regarding the new section 163(j) limitation on business interest deductions.
United States
10 Dec 2018
11
Tax On Termination Payments: The New Law In Practice
In April 2018, the new regime relating to the tax treatment of certain payments made on termination of employment (in particular, payments in lieu of notice (PILONs)) came into effect.
UK
23 Nov 2018
12
Regulations Proposed To Reduce Tax On Income Inclusions Under Section 956
On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations
United States
9 Nov 2018
13
Opportunity Zones: Government Issues Proposed Regulations
On Friday, October 19, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding "Qualified Opportunity Zones."
United States
24 Oct 2018
14
Opportunity Zones: Treasury And IRS Issue Proposed Regulations
The Treasury Department and the IRS issued today highly anticipated proposed regulations regarding "Qualified Opportunity Zones."
United States
23 Oct 2018
15
IRS Announces Study Of Active Trade Or Business Requirement For Spin-Off Transactions
On September 25, 2018, the IRS announced that it is undertaking a study regarding the application of the five-year active trade or business requirement of Section 355(b) ...
United States
12 Oct 2018
16
IRS Issues Guidance Affecting Tax-Exempt Investments In Private Equity Funds
Under the Tax Cuts and Jobs Act (TCJA, December 22, 2017), tax-exempt investors must now calculate unrelated business taxable income (UBTI) separately with respect to each trade or business.
United States
11 Sep 2018
17
Altera: Ninth Circuit Reverses US Tax Court And Holds That Treasury Regulation Allocating Stock-Based Compensation Expenses Is Valid
On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer ...
United States
3 Aug 2018
18
Treasury And IRS Issue Final Regulations On Inversions
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the "Final Regulations").
United States
26 Jul 2018
19
Real Estate Structures Enabling Investors To Use The Section 199A Qualified Business Income Deduction
The article provides a brief analysis of the implications of the new 20 percent business income deduction available to pass-through entities and real estate investment trusts under the Tax Cuts and Jobs Act.
United States
19 Jun 2018
20
The European Commission Investigates U.K. Tax Rules
On October 26, 2017, the EC announced a formal State aid investigation into a U.K. exemption from U.K. anti-tax avoidance rules for certain transactions by multinational groups, the so-called Group Financing Exemption.
European Union
3 May 2018
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