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ARTICLES(39)

"SRLY? You Can’t Be Serious.” “I Am Serious...and Don’t Call Me SRLY.” The IRS Issues Helpful Guidance on the Application of the SRLY Register Rules to Dual Consolidated Losses
August 16, 2011
LEGAL ALERTS/ARTICLES
Author: Michael Reid Miles, William R. Pauls
Law Firm: Eversheds Sutherland (US) LLP

It’s Just a Phase: The “Phased Implementation” of FATCA Under Notice 2011-53
July 21, 2011
LEGAL ALERTS/ARTICLES
Author: Robert S. Chase, Dwaune Lavelle Dupree, Michael Reid Miles, William R. Pauls
Law Firm: Eversheds Sutherland (US) LLP, Eversheds Sutherland (US) LLP, Eversheds Sutherland (US) LLP

IRS Modifies Guidance on Partial Exchanges of Annuity Contracts
July 05, 2011
LEGAL ALERTS/ARTICLES
Author: Thomas A. Gick, Michael Reid Miles, William R. Pauls, W Mark Smith
Law Firm: Eversheds Sutherland (US) LLP, Eversheds Sutherland (US) LLP, Eversheds Sutherland (US) LLP

The Secret Is Out! Proposed Treasury Regulations Shed New Light on the Controlled Group Deferred Loss "Supersecret Rule," Including Its Application to CFCs
April 27, 2011
LEGAL ALERTS/ARTICLES
Author: Reginald J. Clark, Michael Reid Miles, William R. Pauls
Law Firm: Eversheds Sutherland (US) LLP, Eversheds Sutherland (US) LLP

Revision of RIC Tax Rules
December 27, 2010
LEGAL ALERTS/ARTICLES
Author: Michael Reid Miles, Jason M. Rudinsky
Law Firm: Eversheds Sutherland (US) LLP

IRS Concludes That U.S. Lending Activities Conducted Through a Dependent or Independent "Agent" Constitute a U.S. Trade or Business
September 30, 2009
LEGAL ALERTS/ARTICLES
Author: Michael Reid Miles, Christopher Ocasal
Law Firm: Eversheds Sutherland (US) LLP

Permanent Subpart F Rules Proposed for Insurance Companies
May 22, 2009
LEGAL ALERTS/ARTICLES
Author: Michael Reid Miles, Christopher Ocasal
Law Firm: Eversheds Sutherland (US) LLP

Increased Audit Activity Planned for U.S. Federal Excise Tax on Insurance Premiums
April 17, 2009
LEGAL ALERTS/ARTICLES
Author: Michael Reid Miles, Christopher Ocasal
Law Firm: Eversheds Sutherland (US) LLP

Swiss Announce Negotiations for a New Tax Treaty with the United States--New Provisions May Enhance Exchange of Information and Limitation on Benefits Provisions
April 06, 2009
LEGAL ALERTS/ARTICLES
Author: Michael Reid Miles, Christopher Ocasal
Law Firm: Eversheds Sutherland (US) LLP

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