Sullivan & Cromwell LLP

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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...

Iranian Sanctions; United States Designates Iran as a Primary Money Laundering Concern under Section 311 of the USA PATRIOT Act; New Sanctions Target Persons Who Provide Goods, Services, Technology or Support that Contributes to Iran’s Development of Petroleum Resources or Production of Petrochemical Products
Andrew S. Baer,Elizabeth T. Davy,Kelly Helt,Eric J. Kadel,Andrea R. Tokheim, December 7, 2011
In response to recent revelations regarding Iran’s nuclear weapons program, and in advance of significant legislation currently under consideration by the U.S. Congress, the United States has imposed several new sanctions measures targeting Iran.

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...

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