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Kaye Scholer LLP New York, MA Document Search Results (24) Show: results per page Sort by:  | IRS Issues Regulations on Withholding on “Dividend Equivalents”
Kaye Scholer LLP;
Legal Alert/Article January 27, 2012, previously published on January 26, 2012 In March of 2010, the Hiring Incentives to Restore Employment (“HIRE”) Act added a new Section, 871(m), to the Internal Revenue Code of 1986, as amended (the “Code”). Under Section 871(m) of the Code, “dividend equivalent” payments made to nonresident aliens and...
| | New Year’s Cheer: A Defendant’s Removal Wishlist Fulfilled
Kaye Scholer LLP;
Legal Alert/Article January 9, 2012, previously published on January 5, 2012 Congress and President Obama delivered early New Year’s cheer for defendants who often find themselves venued in undesirable state courts. On December 7, 2011, President Obama signed into law a rare expansion of removal rights for defendants in the “Federal Courts Jurisdiction and Venue...
| | Important Modifications to Accredited Investor Definition — Effective Late February 2012
Peter Danias, Lynn Toby Fisher, Diane Holt Frankle; Kaye Scholer LLP;
Legal Alert/Article December 28, 2011, previously published on December 23, 2011 On December 21, 2011, the Securities and Exchange Commission adopted amendments to the definition of an “accredited investor” under Regulation D, promulgated under the Securities Act of 1933. This amendment implements the requirements of the Dodd-Frank Wall Street Reform and Consumer...
| | IRS Issues Further Guidance on the Reporting ofForeign Financial Assets
Jakub Kucharzyk, Jeffrey D. Scheine; Kaye Scholer LLP;
Legal Alert/Article December 22, 2011, previously published on December 19, 2011 The IRS has issued temporary regulations that give further guidance on the reporting of taxpayers’ foreign financial assets beginning with the 2011 tax year and has indicated that it will soon release final versions of the necessary reporting form and associated instructions. Based on the new...
| | IRS to Announce Amnesty for Non-Compliant US Citizens Living in Canada
Jakub Kucharzyk, Jeffrey D. Scheine, Sydney E. Unger; Kaye Scholer LLP;
Legal Alert/Article December 12, 2011, previously published on December 6, 2011 An IRS spokesman recently indicated that the IRS intends to announce an amnesty whereby certain Americans living in Canada who have inadvertently failed to file US tax returns and comply with other US reporting rules will be able to come forward in exchange for a waiver of potentially severe...
| | IRS Issues Final Regulations on Partnership Debt-for-Equity Exchanges
Willys H. Schneider; Kaye Scholer LLP;
Legal Alert/Article December 1, 2011, previously published on November 30, 2011 Summary: Debtor partnerships often transfer an interest in such partnership to a creditor in satisfaction of the partnership’s recourse or nonrecourse debt (known as a “debt-for-equity” exchange). Debt-for-equity exchanges occur for a number of reasons. The U.S. federal income tax...
| | Aloha Discounts or How Not to Operate a Family Limited Partnership
Michael Ben-Jacob, Dana Mark; Kaye Scholer LLP;
Legal Alert/Article December 1, 2011, previously published on November 28, 2011 Summary: In Estate of Paul H. Liljestrand v. Commissioner, decided on November 2, the Tax Court recently addressed the issue of whether assets the decedent transferred to a family limited partnership were includible in the decedent’s estate under Internal Revenue Code Section 2036. The...
| | SEC and CFTC Approve Systemic Risk Reporting on Form PF
Kaye Scholer LLP;
Legal Alert/Article November 8, 2011, previously published on November 3, 2011 As of October 31, 2011, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC”) jointly approved proposed Rule 204(b)-1 under the Investment Advisers Act of 1940 (the “Rule”). As adopted, the Rule made two...
| | IRS Issues Proposed Section 892 Regulations
Gary J. Gartner, David A. Sausen, Jeffrey D. Scheine, Willys H. Schneider; Kaye Scholer LLP;
Legal Alert/Article November 8, 2011, previously published on November 4, 2011 Earlier this week, the IRS issued proposed Treasury Regulations (the “Proposed Regulations”) that provide guidance relating to the taxation of the income of foreign governments from investments in the United States under Section 892 of the U.S. Internal Revenue Code of 1986, as amended....
| | SEC’s Conflicts of Interest Rule Proposal Preserves Considerable SEC Discretion and Creates Market Uncertainty
William J. Fellerhoff, Karsten P. Giesecke, Daniel J. Hartnett, Eric P. Marcus, Henry G. Morriello; Kaye Scholer LLP;
Legal Alert/Article October 14, 2011, previously published on October 12, 2011 On Monday, September 19, 2011, the Securities and Exchange Commission (the “Commission”) issued its Release No. 34-65355 (the “Proposing Release”) proposing for comment a new Rule 127B (the “Proposed Rule”) under the Securities Act of 1933, as amended (the...
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