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Searching Content indexed under Corporate Tax by Orrick ordered by Published Date Descending.
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1
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
2
Newsletter Corporate - February 2017
The following provides a summary of issues that have attracted attention in the German M&A practice recently.
Germany
8 Mar 2017
3
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
4
New Countries Eligible For Italy's White List
The Italian Government published the Ministerial Decree of 9 August 2016 (the "Decree") that amended the list of countries and territories "allowing an adequate exchange of information with the Italian Tax Authorities"...
Italy
14 Sep 2016
5
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
6
IRS Issues Further Guidance on "Start of Construction" Requirement for Renewable Energy Tax Credits, Including Continuity Requirement
On May 5, 2016, the IRS released Notice 2016-31, which provides additional guidance on the "start of construction" requirements for the production tax credit (PTC) and investment tax credit (ITC) in lieu of the PTC.
United States
8 Jul 2016
7
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
8
Treasury Issues Temporary Regulations To Address Inversion Problems
On April 4, 2016, the U.S. Treasury issued temporary regulations to make it increasingly difficult for companies to invert.
United States
18 Apr 2016
9
Patent Box - Ultimi Aggiornamenti Dall'Agenzia Delle Entrate
Il "Patent Box" consente alle società che svolgono attività di Ricerca & Sviluppo di optare, a partire dall'esercizio d'imposta 2015, per un regime di tassazione agevolata dei redditi generati dallo sfruttamento diretto o indiretto di risorse di proprietà intellettuale.
Italy
7 Apr 2016
10
European Commission Unveils Tax Transparency Package
The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national corporations.
European Union
30 Mar 2015
11
Diverted Profits Tax And You: What Does It Mean?
The UK is on course to enact a new tax (the "DPT") with extraterritorial scope which will apply to profits arising on or after 1 April 2015 and will be applied at a rate of 25%.
UK
5 Feb 2015
12
Distressed Debt - UK Tax Changes
We discuss below changes to UK tax law in respect of corporate debt which take effect from the beginning of this year which will improve the UK tax position for distressed debt of a UK company.
UK
29 Jan 2015
13
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
14
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
15
Tax Issues For German Startups Looking For US-Investors
VC-raising through a U.S. entity may result in disclosure of hidden assets.
Germany
18 Jun 2014
16
Tax Reform Bill Proposal - Much Ado About Nothing
As widely reported, on February 26, 2014, U.S. House of Representatives Committee on Ways and Means Chairman Dave Camp (R-MI) released the proposed Tax Reform Act of 2014 (the "Camp Proposal").
United States
20 Apr 2014
17
Annual ISO And ESPP Information And Reporting Requirements
For any exercise of an incentive stock option or transfer of a share previously purchased pursuant to a tax-qualified employee stock purchase plan where the purchase price paid for the share was (a) less than 100% of the fair market value on the date of grant or (b) not fixed or determinable on the date of grant, the Internal Revenue Code requires companies.
United States
27 Jan 2014
18
Post-Issuance Tax Compliance And Continuing Disclosure Responsibilities For Issuers And Borrowers Of Tax-Exempt Bonds
Over the past few years, the tax-exempt bond market has been under heightened scrutiny by various regulators.
United States
27 Oct 2013
19
Stock Options Grant Timing: Is Your Company at Risk?
The Securities and Exchange Commission, and United States Attorney's Offices in New York, California and Massachusetts currently are investigating if the abnormal return patterns associated with certain stock option grants are attributable to improper backdating of such grants.
United States
16 Jun 2006
20
Proposed Amendments to The Executive Pay Disclosure Rules: Common Sense and What Compensation Committees Should be Thinking About
The recently proposed SEC amendments will require the disclosure of almost all aspects of executive pay and benefits and also require more indepth disclosure of the Compensation Committee’s philosophy and rationale for its decision making.
United States
30 May 2006
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