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Adobe PDFThe IRS and Treasury Issue New Anti-Inversion Guidance
James R. Barry, Jason S. Bazar, Lee Morlock; Mayer Brown LLP;
Legal Alert/Article
September 26, 2014, previously published on September 25, 2014
Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service (“IRS”) and the Treasury Department (“Treasury”) released Notice 2014-52 (“Notice”) on September 22, 2014, describing new...

 

Adobe PDFIRS and Treasury Issue Long-Awaited Guidance on Corporate Inversions and “Disqualified Stock”
James R. Barry, Jason S. Bazar, Michael K. Marion, Lee Morlock; Mayer Brown LLP;
Legal Alert/Article
January 31, 2014, previously published on January 27, 2014
On January 16, 2014, the Internal Revenue Service (the “IRS”) and the Treasury Department (the “Treasury”) issued longawaited temporary and proposed regulations under Code section 7874 relating to corporate inversions (the “Regulations”).

 

HTMLNew York State Seeks to Recharacterize a Nonresident Partner's "Carried" Interest
Jason S. Bazar, Matthew DiDonato, C. Wells Hall; Mayer Brown LLP;
Legal Alert/Article
July 22, 2010, previously published on July 7, 2010
In an effort to balance the New York State budget, Governor Paterson is supporting a proposal to amend the state’s tax law with respect to the treatment of carried interest income of nonresident fund managers from an investment fund located in New York as income for the performance of...

 

HTMLIRS Chief Counsel Memorandum on Effectively Connected Income if Loan Origination Activity is conducted through a U.S. Agent
James R. Barry, Jason S. Bazar, Russell E. Nance, Daniel R. Read; Mayer Brown LLP;
Legal Alert/Article
October 1, 2009, previously published on September 24, 2009
On September 22, 2009, the Office of Chief Counsel of the Internal Revenue Service (the "Service") issued a memorandum to the Director of Field Operations for Financial Services in Manhattan (the "Memorandum") setting forth its position and legal analysis with respect to certain...

 

Adobe PDF2009 Economic Stimulus Package: Certain Debt Repurchases by Businesses Granted Relief from Tax on Cancellation of Indebtedness Income
James R. Barry, Jason S. Bazar, Russell E. Nance; Mayer Brown LLP;
Legal Alert/Article
March 9, 2009, previously published on February 17, 2009
The economic stimulus package, signed into law on February 17, 2009, grants corporations and businesses that repurchase their debt at a discount a right, under certain circumstances, to elect to defer the recognition of their cancellation of indebtedness (COD) income for up to five years.

 

Adobe PDFIRS Issues Guidance to Address Transactions in Distressed Market Conditions
James R. Barry, Jeffrey P. Cantrell, Timothy C. Sherck, Jason S. Bazar, Russell E. Nance; Mayer Brown LLP;
Legal Alert/Article
October 16, 2008, previously published on October 3, 2008
The Internal Revenue Service (the "Service") recently issued guidance intended to address certain situations arising as a consequence of the current market developments.