David C. Spitzer

Corporate Reorganizations - Measuring Continuity of Interest: IRS Proposes New Regulations for Measuring Continuity of Interest in Corporate Reorganizations
Avi S. Alter,Ronald E. Creamer,David C. Spitzer, December 27, 2011
On December 16, 2011, the Internal Revenue Service (the “IRS”) and Treasury Department issued final and proposed regulations (“the Final Regulations” and “the Proposed Regulations,” respectively) that generally provide rules for the proper timing of the valuation...

Partnership Debt-For-Equity Exchanges: IRS Issues Final Regulations on Cancellation of Indebtedness Income and Other Consequences of an Exchange of Partnership Debt for Partnership Equity
Donald L. Korb,Andrew S. Mason,Kevin Salinger,David C. Spitzer,S. Eric Wang, November 25, 2011
The Internal Revenue Service (the “IRS”) recently released final regulations (the “Final Regulations”) relating the federal income tax consequences of the transfer of a partnership interest by a partnership to a creditor in satisfaction of the partnership’s...

U.S. Income Taxation of Foreign Governments: IRS Issues Proposed Regulations on the U.S. Taxation of the U.S. Investment Income of Foreign Governments and Entities Wholly Owned by Foreign Governments
Ronald E. Creamer,Donald L. Korb,Andrew S. Mason,Dexter D.J. Samida,David C. Spitzer,Davis J. Wang,S. Eric Wang, November 9, 2011
Under Section 892 of the Internal Revenue Code, a foreign government is exempt from U.S. federal income taxation on certain investment income. Entities wholly owned by a foreign government - such as sovereign wealth funds and pension plans - that meet certain requirements are generally able to rely...