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Document(s) published by this organization: 144


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Adobe PDFVolcker Rule: Federal Reserve Issues Statement of Intent to Extend the Volcker Rule Conformance Period Through July 21, 2017 for CLOs
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 8, 2014
Late yesterday afternoon, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) released a statement regarding the treatment of collateralized loan obligations (“CLOs”) under Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act...

 

Adobe PDFInternational Tax Cooperation: UK Sets Out Its Priorities for the OECD Base Erosion and Profit Shifting (BEPS) Project
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 9, 2014
The UK government has published a paper setting out in detail its position on the OECD’s Action Plan on Base Erosion and Profit Shifting.

 

Adobe PDFNew York’s Highest Court Strengthens Forum Non Conveniens Doctrine in Cases Having Peripheral Connection to New York Banking System: Mashreqbank PSC v. Ahmed Hamad Al Gosaibi & Brothers Company
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 10, 2014
In an opinion issued on April 8, 2014, the New York Court of Appeals unanimously dismissed on forum non conveniens grounds a case arising from a foreign exchange transaction between a bank in the United Arab Emirates and a general partnership in Saudi Arabia, where the only nexus between the...

 

Adobe PDFNew Guidance on Same-Sex Marriage Under Tax-Qualified Retirement Plans: IRS Notice 2014-19 Requires Prospective Application of the Windsor Decision as of June 26, 2013 and Compliance with “State of Celebration” Approach to Recognizing Marriages as of September 16, 2013
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 7, 2014
On April 4, 2014, the Treasury Department and the IRS issued Notice 2014-19 (the “Notice), which provides long-awaited guidance on the effect of the Supreme Court’s decision in United States v. Windsor on tax-qualified retirement plans. In Windsor, 133 S. Ct. 2675 (2013), the Supreme...

 

Adobe PDFEstate, Gift and Trust Provisions in New York State 2014-15 Budget: New York State 2014-15 Budget Makes Changes to the Taxation of Estates and Gifts and the Income Taxation of Certain Trusts
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 4, 2014
On March 31, 2014, Governor Andrew Cuomo signed into law the New York State 2014-15 Budget (the “Budget”). This memorandum describes the changes made by the Budget to the taxation of estates and gifts and the income taxation of certain trusts. We will be distributing a separate...

 

Adobe PDFUK Employment Arrangements: UK Revises Proposed Tax Measures Against Dual Contracts
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 4, 2014
The UK government has published this year’s Finance Bill, which contains revised draft legislation to “end the abuse of dual contracts”. Dual contracts have in particular been used by employees resident, but not domiciled, in the United Kingdom to benefit from the UK’s...

 

Adobe PDFEU Competition Law: European Commission Adopts New Technology Transfer Block Exemption Regulation and Guidelines
Sullivan Cromwell LLP;
Legal Alert/Article
April 4, 2014, previously published on April 1, 2014
The principal rules of EU competition law relating to technology licensing are set out in the European Commission’s Technology Transfer Block Exemption Regulation (“TTBER”) and Guidelines on Technology Transfer Agreements (“Guidelines”) (collectively, the “TTBER...

 

Adobe PDFTax Court Addresses Material Participation by Trusts: Tax Court Holds That Services Performed by Trustees Who Are Also Employees May Be Taken into Account in Determining Material Participation for Passive Loss Purposes; Holding Also Relevant for 3.8% Net Investment Income Tax
Sullivan Cromwell LLP;
Legal Alert/Article
April 4, 2014, previously published on March 31, 2014
On March 27, 2014, in Frank Aragona Trust et al. v. Comm’r, the Tax Court ruled that, in determining whether a trust’s activities are “passive” for purposes of the passive activity loss rules, (i) a trust can qualify for the material participation exception relating to...

 

Adobe PDFIRS Issues Third Directive Regarding the Issuance and Enforcement of Information Document Requests
Sullivan Cromwell LLP;
Legal Alert/Article
April 3, 2014, previously published on March 5, 2014
The Commissioner of the Internal Revenue Service (“IRS”) Large Business and International Division (“LBI”) issued a directive on February 28, 2014 (the “February Directive”), to revenue agen ts responsible for audits conducted by LBI. LBI oversees audits of...

 

Adobe PDFChairman Camp’s Discussion Draft of Tax Reform Act of 2014 and President Obama’s Fiscal Year 2015 Revenue Proposals
Theodore D. Holt, Donald L. Korb, Andrew S. Mason, Andrew P. Solomon, S. Eric Wang; Sullivan & Cromwell LLP;
Legal Alert/Article
April 3, 2014, previously published on March 25, 2014
On February 26, 2014, Ways and Means Committee Chairman Dave Camp released a discussion draft of tax reform legislation entitled the “Tax Reform Act of 2014” (the “Discussion Draft”). Although the Discussion Draft is unlikely to be enacted in its current form, some or all of...

 


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