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Dec 4, 2024 | 
mondaq.com | Larry Crouch |Ryan Bray |Matthew Brown |José Germano Rego |José Márcio Rêgo
AO
A&O Shearman
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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets.
This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
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Dec 4, 2024 | 
jdsupra.com | Ryan Bray |Matthew Brown |Larry Crouch
On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of 1986, as amended (the “Code,” and such proposed regulations, the “Proposed Regulations”), addressing certain core aspects of the previously taxed earnings and profits (“PTEP”) system.
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Aug 13, 2024 | 
mondaq.com | Larry Crouch |Ryan Bray |Jay Singer |Matthew Brown
CONTRIBUTING SINCE APRIL 2002
Our success is built on our clients’ success. We have a long and distinguished history of supporting our clients wherever they do business, from major financial centers to emerging and growth markets. We represent many of the world’s leading corporations and major financial institutions, as well as emerging growth companies, governments and state-owned enterprises, often working on ground-breaking, precedent-setting matters.
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Jan 8, 2024 | 
jdsupra.com | Ryan Bray |Matthew Brown |Larry Crouch
On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the treatment of notional basis adjustments under section 961(c)[1] when all of the stock of a lower-tier “controlled foreign corporation” within the meaning of section 957(a) (“CFC”) is transferred by a CFC to a U.S. acquiring corporation in a section 332 liquidation or certain...
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Dec 28, 2023 | 
jdsupra.com | Ryan Bray |Matthew Brown |Larry Crouch
On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”).[1] The Treaty provides for reduced withholding tax rates on income such as dividends, interest and royalties with the goal of reducing double taxation and increasing commerce and investment between the United States and Chile.
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Dec 28, 2023 | 
lexology.com | Larry Crouch |Ryan Bray |Todd Lowther |Jay Singer |Matthew Brown |José Germano Rego | +1 more
On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”).[1] The Treaty provides for reduced withholding tax rates on income such as dividends, interest and royalties with the goal of reducing double taxation and increasing commerce and investment between the United States and Chile.
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Dec 26, 2023 | 
jdsupra.com | Ryan Bray |Matthew Brown |Larry Crouch
On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate Alternative Minimum Tax (“CAMT”) with respect to controlled foreign corporations within the meaning of section 957(a)[1] (“CFCs”) and affiliated groups of corporations filing consolidated tax returns (“Consolidated Groups”).
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Dec 18, 2023 | 
jdsupra.com | Ryan Bray |Matthew Brown |Larry Crouch
On December 11, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”), announcing their intention to issue proposed regulations that will address the interaction of certain provisions under the Organisation for Economic Co-operation and Development’s (“OECD’s”) Global Anti-Base Erosion Rules (Pillar Two) (“Pillar Two Rules”)[1] with the United States’ foreign tax credit (“FTC”) and dual consolidated loss (“DCL”)...
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Oct 25, 2023 | 
jdsupra.com | Ryan Bray |John Cannon III |Larry Crouch
On October 17, 2023, the U.S. Internal Revenue Service (IRS) updated its Internal Revenue Manual (IRM)[1] to fully incorporate into the IRM certain e-signature policies and procedures permitting the use of electronic signatures on certain forms, including elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,”[2] and such elections, “Section 83(b) Elections”).
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May 28, 2023 | 
mondaq.com | Ryan Bray |Larry Crouch |Todd Lowther |Gillian Emmett Moldowan
On May 3, 2023, the Tax Court released a memorandum opinion in
ES NPA Holding LLC v. Commissioner1 holding
that the taxpayer's indirect receipt of a profits interest in a
lower-tier partnership qualified as a non-taxable event under the
safe harbor provided in Rev. Proc. 93-27.2 The opinion
provides a well-reasoned application of the profits interest safe
harbor that puts to rest certain unsettled tax issues relating to
the use of such structures.
