Donald L. Korb

Foreign-Targeted Bearer Bonds: IRS Issues Transitional Guidance on the Upcoming “Bearer Bond” Repeal
Jeffrey D. Hochberg,Donald L. Korb,Andrew S. Mason,Michael Orchowski,Andrew P. Solomon,S. Eric Wang, March 19, 2012
On March 7, 2012, the IRS issued Notice 2012-20 (the “Notice”), which provides transitional guidance regarding the upcoming sunset of the U.S. tax law provisions that permit the issuance of “foreign-targeted bearer” obligations. The rules set forth in the Notice will...

Transfer Pricing Developments - Cost Sharing Arrangements: IRS Finalizes Cost Sharing Regulations & Issues Supplemental Guidance on the Application of the Income Method
Aditi Banerjee,James R. Gadwood,Donald L. Korb,Adrienne D. Maxwell,Andrew P. Solomon,S. Eric Wang, December 29, 2011
On December 16, 2011, the Internal Revenue Service (the “IRS”) and the Treasury Department finalized regulations (the “Final Regulations”) under Section 482 of the Internal Revenue Code of 1986, as amended (the “Code”), relating to cost sharing arrangements with...

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...