Ryan Bray

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Articles

Treasury And The IRS Proposed Regulations On Previously Taxed Earnings And Profits

Dec 4, 2024 | mondaq.com | Larry Crouch |Ryan Bray |Matthew Brown |José Germano Rego |José Márcio Rêgo

AO A&O Shearman More 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.
Treasury and the IRS proposed regulations on previously taxed earnings and profits | JD Supra

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.
IRS Creates A Standardized Section 83(b) Election Form

Nov 18, 2024 | mondaq.com | Ryan Bray |Jai Anand Garg |Matthew Behrens |Austin Jones

On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620,1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the "Code," and such elections, "Section 83(b) Elections") for taxpayers to accelerate taxation upon the receipt of unvested property received in connection with the performance of services.
Travel's Untapped Potential

Sep 1, 2024 | grouptravelleader.com | Ryan Bray |Brian Jewell

Is travel capable of changing more than just your scenery? On the surface, group travel is a straightforward proposition. People want to travel, and tour companies make their trips more convenient by bundling hotels, meals, transportation and sightseeing. Tour directors handle the logistics; local guides make faraway places feel safe and accessible. At the end of the trip, everyone goes home with souvenirs, photos and some fun memories.
Shearman & Sterling LLP

Aug 13, 2024 | mondaq.com | Larry Crouch |Ryan Bray |Jay Singer |Matthew Brown

CONTRIBUTING SINCE APRIL 2002 Our success is built on our clientsâ€™ 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 worldâ€™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.
Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax liabilities

Aug 12, 2024 | lexology.com | Larry Crouch |Ryan Bray |Jay Singer |Matthew Brown |José Germano Rego |José Márcio Rêgo

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503[1] (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the Global Anti-Base Erosion Rules (Pillar Two) (“Pillar Two Rules”),[2] among other DCL issues.[3] If finalized, the Proposed Regulations would increase the relevance of the DCL rules for many U.S. consolidated groups with foreign affiliates either above or below such U.S....
ROCK VETERANS WIRE TALK SELF-TITLED EXPECTATIONS

Aug 9, 2024 | digboston.com | Ryan Bray

"In the end, its got to be about subtlety."It's interesting hearing that take on songwriting from Wire frontman Colin Newman, especially since his band has built its iconic reputation on experimenting and cutting against the grain. But after four decades of pushing the envelope, it's amusing that the most interesting and novel thing for Newman to do on the band's 13th studio effort was retreat to a more personal, songwriter-based manner of penning new material.
YO LA TENGO @ THE WILBUR, 10/3

Aug 9, 2024 | digboston.com | Ryan Bray

Thinking back to the last time I saw Yo La Tengo, I just remember it was loud. Their tour in support of 2009's somewhat-underrated Popular Songs brought them to the Wilbur Theater, and although some of the band's breezier, less guitar driven stuff was in play, it was a full band set up. Many beers were had if I recall, and I gravitated to the noise. For whatever reason it took me north of six years to catch indie rock's crown jewel in the act again.
THE OKAY WIN ON OPENING FOR STEPHEN MALKMUS & THE JICKS

Aug 9, 2024 | digboston.com | Ryan Bray

The few hundred people huddled inside The Sinclair clutching their PBRs are watching The Okay Win with the kind of easy temperament that greets most opening bands. It's a mixture of cool relaxation coupled with mild appreciation, subtle head nods, end-of-song applause and all. They like what they hear, but the band is not the night's main draw. But while those in attendance might not know it, a great story is unfolding onstage before everyone's eyes.
THE SUPERGRASS FRONTMAN IS A CHANGED MAN

Aug 9, 2024 | digboston.com | Ryan Bray