Cecelia Philipps Horner

Treasury Issues Proposed Regulations with Safe Harbor for Sovereign Wealth Funds
Cecelia Philipps Horner,George C. Howell,Mark A. Melton,Joshua Z. Mishoe,Kendal Aylor Sibley,B. Cary Tolley, November 22, 2011
On November 2, Treasury proposed regulations (the “Proposed Regulations”) under section 892 of the Internal Revenue Code (the “Code”) that eliminate the “all or nothing” rule that previously applied for determining whether an entity is a “controlled...

Stop Tax Haven Abuse Act
Cecelia Philipps Horner,George C. Howell,Alexander G. McGeoch,Mark A. Melton,Joshua Z. Mishoe,Kendal Aylor Sibley,B. Cary Tolley, August 1, 2011
On July 12, 2011, U.S. Senator Carl Levin, a Michigan Democrat, proposed a revised version of an international tax reform bill referred to as the Stop Tax Haven Abuse Act (the “Proposed Legislation”). The Proposed Legislation makes a number of changes to the current tax treatment of...

IRS Provides Further Guidance on New Withholding and Reporting Provisions
Cecelia Philipps Horner,George C. Howell,Alexander G. McGeoch,Mark A. Melton,Joshua Z. Mishoe,Kendal Aylor Sibley,B. Cary Tolley, April 26, 2011
On April 8, 2011, the Internal Revenue Service (“IRS”) issued Notice 2011-34 (the “Notice”), which supplements and revises previous IRS guidance in Notice 2010-60 regarding the implementation of the new withholding and reporting provisions in the Hiring Incentives to Restore...