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1
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
2
Paris Team Authors Article About Definition Of Abuse Of Right And Guarantee Against Changes In Tax Doctrine
Paris senior counsel Noël Chahid-Nouraï and partner Laurent Olléon, formerly members of the tax chambers of Conseil d'État, France's highest administrative court ...
France
11 Feb 2019
3
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
4
Una nuova Cassazione sulla tassazione della cessione di quote ai fini della imposta di registro
Con la Sentenza n. 11877, depositata in data 12 maggio 2017, la Corte di cassazione suscita nuovi dubbi sulla applicazione della imposta di registro, assoggettando al regime proprio della cession...
Italy
6 Jul 2017
5
Outline For Discussion Of New Issue Price Rules
New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon.
United States
6 Jun 2017
6
Il Nuovo Regime Fiscale Dei Piani Di Co-Investimento Di Amministratori E Dipendenti
L'articolo 60 del d.l. n. 50 del 24 aprile 2017, pubblicato in G.U. 24 aprile 2017 (di seguito "Decreto"), disciplina il regime fiscale applicabile ai redditi derivanti dalla partecipazione ad OICR...
Italy
16 May 2017
7
La definizione agevolata delle controversie tributarie
L'articolo 11 del d.l. n. 50 del 24 aprile 2017, pubblicato in GU 24 aprile 2017, introduce e disciplina la c.d. "Definizione agevolata delle controversie tributarie".
Italy
15 May 2017
8
German Corporate Law Update: Important Changes In Acquisitions And Investments
Less than 18 months from now, the new European Data Privacy Regulation ("GDPR") will take effect.
Germany
24 Mar 2017
9
Introduction To Tax For Public Finance – Tax Presentation
Topics covered: Introduction to Tax for Public Finance, Tax-Exemption for State and Local Bonds, Inefficiency in Tax-Exempt Subsidy, Types of Tax-Exempt Bonds, Overview of Federal Income Tax Restrictions...
United States
9 Mar 2017
10
IRS Allows 401k Plan Safe Harbor And ADP/ACP Corrective Contributions To Be Funded From Forfeitures
The IRS just issued a proposed regulation that allows safe harbor contributions to a 401(k) plan, or employer contributions used to correct a failed ADP or ACP test, to be funded from forfeitures.
United States
9 Mar 2017
11
Wildenstein Art Dynasty Heirs Acquitted Of Tax Fraud
Orrick's Jean-Pierre Martel, Anne-Sophie Kerfant and Diane Lamarche achieved a tremendous victory last week in a decision that has been hailed as a "surprise verdict" by the New York Times.
France
6 Mar 2017
12
New Lending Opportunities For EU Alternative Investment Funds In Italy
On 23 December 2016, the Bank of Italy supplemented the regulation on the collective investment management (the "Regulation") which, inter alia, implements article 46-ter of Legislative Decree. n. 58/1998...
Italy
6 Mar 2017
13
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
14
IRS Updates Golden Parachute Audit Guide
The 2017 ATG expands and updates the list of documents for IRS examiners to review in connection with a golden parachute examination.
United States
21 Feb 2017
15
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
16
Annual Reporting Requirements For Incentive Stock Options And Employee Stock Purchase Plans - 01.18.17
For (1) any exercise of an incentive stock option ("ISO") during 2016 or (2) transfer during 2016 of a share previously purchased pursuant to a tax-qualified employee stock purchase plan ("ESPP").
United States
25 Jan 2017
17
Nine Key Tax Issues For Startup Founders To Consider
Grady Bolding, a partner in Orrick's Tax team in San Francisco, recently co-authored an article with Orrick alum Richard Harrochs, now a Managing Director and Global Head of M&A...
United States
14 Nov 2016
18
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
19
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
20
Good News From The IRS On 401(K) Safe Harbor Plans
Safe harbor 401(k) plans are attractive because they are not required to perform annual nondiscrimination testing.
United States
9 Mar 2016
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