Ronald E. Creamer, Jr.

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...

Proposed Regulations Seek to Ease Compliance with the Loss Trafficking Rules: Treasury Issues Notice of Proposed Rulemaking Limiting the Application of the Section 382 Segregation Rules in Certain Circumstances
Ronald E. Creamer,Michael J. Rosenthal,S. Eric Wang, December 1, 2011
Under Section 382 of the Internal Revenue Code, a corporation’s use of net operating losses is limited if there is an “ownership change.” On November 22, 2011, the Department of Treasury issued a Notice of Proposed Rulemaking (the “Notice”) containing proposed...

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...