Searching Content indexed under Tax by Cadwalader, Wickersham & Taft LLP ordered by Published Date Descending.
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Using Irish Treaty Funds To Avoid US Taxes In Direct Lending
Private debt funds raised more than $100 billion for the fourth consecutive year in 2018,[1] and reached their highest level of fundraising on record during the first half of 2019.[2]
United States
10 Oct 2019
Treasury Proposes Second Set Of Regulations On Opportunity Zones
The U.S. Treasury Department ("Treasury") clarified the Opportunity Zone tax incentive through a second set of proposed regulations.
United States
16 May 2019
DOJ And IRS Seek Information On Finnish Individuals Using U.S. Payment Cards
The DOJ petitioned the U.S. District Court for the Western District of North Carolina to authorize IRS summonses to uncover the identities of Finnish residents using U.S.-issued payment cards in Finland.
United States
16 May 2019
ICI Opposes NY State Bills To Reduce Rebate Of Stock Transfer Sales Tax
The Investment Company Institute ("ICI") expressed opposition to New York State bills that would reduce the rebate of stock transfer sales tax from 100 percent to 60 percent.
United States
23 Apr 2019
Private Client USA | 2019
U.S. domiciliaries are generally subject to U.S. Federal estate tax, gift tax and generation-skipping transfer tax (the "GST tax") in the same manner as U.S. citizens
United States
26 Mar 2019
Taxing Times: The Death Of LIBOR
Regulators have cautioned that LIBOR—which serves as a reference rate for approximately $35 trillion dollars of debt and derivatives—will be phased out as early as the end of 2021.
United States
28 Feb 2019
Tax Update: IRS Trims Back FATCA
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA.
United States
20 Dec 2018
IRS Proposes Restricting "Deemed Repatriations" By Controlled Foreign Corporations
The U.S. Treasury Department and the IRS proposed regulations that affect certain U.S. corporations that own, or are treated as owning, stock in foreign corporations.
United States
13 Nov 2018
Cadwalader Attorneys Analyze Proposed Regulations Regarding Opportunity Zones
Cadwalader attorneys analyzed proposed regulations, issued on October 19, 2018 by the IRS and U.S. Treasury Department ("Treasury"), relating to the new Opportunity Zone program.
United States
7 Nov 2018
UK Budget 2018 – Key Tax Measures
The Chancellor of the Exchequer delivered the United Kingdom ("UK") Budget for 2018 on 29 October 2018.
United States
6 Nov 2018
Federal Register: Treasury Proposes Regulations On Opportunity Zones
An IRS and U.S. Treasury Department ("Treasury") notice of proposed rulemaking relating to the new Opportunity Zone tax incentive was published in the Federal Register.
United States
2 Nov 2018
Treasury Issues Proposed Regulations On Opportunity Zones
On October 19, 2018, the Internal Revenue Service (the "IRS") and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program.
United States
1 Nov 2018
Treasury Proposes Regulations On Opportunity Zones
The U.S. Treasury Department ("Treasury") proposed regulations relating to the new Opportunity Zone tax incentive.
United States
25 Oct 2018
New IRS Commissioner Sworn In
Charles Rettig was sworn in as the 49th Commissioner of the IRS. Prior to his appointment, Mr. Rettig was a tax attorney at the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C.
United States
9 Oct 2018
IRS Extends Effective Date And Phase-In Period For Dividend Equivalent Rules
The Internal Revenue Service ("IRS") delayed implementing certain rules that are intended to prevent non-U.S. persons from using derivative instruments to avoid U.S. withholding tax on U.S. equities.
United States
27 Sep 2018
New IRS Guidance Regarding Section 162(m)'s Deduction Limitation For Executive Compensation – Increased Complexity And Reduced Availability Of Grandfathering
Another important issue addressed by the Notice is the interpretation of the amendments made to the definition of "covered employee."
United States
19 Sep 2018
The Taxation Of CRE-CLOs
Commercial real estate collateralized loan obligations (CRE-CLOs) are growing in popularity as a way to securitize mortgage loans.
United States
13 Sep 2018
SFIG Comments On The Application Of New Partnership Withholding Rules To Certain Securitizations
The Structured Finance Industry Group ("SFIG") submitted comments to the Internal Revenue Service ("IRS") regarding the application of section 1446(f) of the Internal Revenue Code to middle-market collateralized loan obligations ("MM CLOs") and other securitizations.
United States
11 Sep 2018
UK Corporate Interest Restriction Rules – Keeping Pace With Change
Adam Blakemore and Catherine Richardson reflect on the development of, and practical considerations associated with, the existing legislation, and provide guidance on some...
18 May 2018
FERC Disallows Income Tax Component In MLP-Owned Partnership Pipeline Cost-Of-Service Rates
The Federal Energy Regulatory Commission ("FERC") will no longer allow partnership oil and natural gas pipelines owned by a master limited partnership ("MLP") to recover an income tax allowance ...
United States
27 Mar 2018
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