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DLA Piper: Tax reform - high priority for President and Congress in 2013

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Tax reform - high priority for President and Congress in 2013

DLA Piper
December 14, 2012
2 pages

Corporate Tax Legislation

Gibson Dunn: Obama Administration's Fiscal Year 2014 Revenue Proposal Would Facilitate Investment in U.S. Real Property by Foreign Pension Funds

May 23, 2013 FY2014 Budget & Greenbook

Paul Hastings: Section 336(e): Final Regulations Related to Deemed Asset Purchases Provide New Flexibility in Structuring Acquisitions

May 23, 2013 Section 336(e) & Disposition of Subsidiary Stock

Simpson Thacher: Final Regulations under Section 336(e)

May 23, 2013 Section 336(e) & Disposition of Subsidiary Stock

Fulbright & Jaworski: Opportunities for Owners of Early Stage Businesses Under the 2010 Tax Relief Act

McDermott Will & Emery: Year-End Legislation Extends Key Provisions for Businesses, Provides 100 Percent Expensing for Certain Assets and Enacts New Foreign Procurement Excise Tax [Subpart F & Look-through rule]

Paul Hastings: Certain Exceptions to Subpart F Income Are Extended for Two Additional Years Under The Tax Relief Act of 2010

FY2012 Budget & Greenbook

Edwards Angell: New Short Term FY 2011/ FY 2012 Budget/ Next Steps

Orrick: The Obama Administration’s Fiscal Year 2012 Revenue Proposals

Sullivan & Cromwell: President Obama’s Fiscal Year 2012 Revenue Proposals: Proposals Relating to International Taxation

H.R. 1586 Limits Use of Foreign Tax Credits

McDermott Will & Emery: Congress Enacts International Tax Legislation, Limits Use of Foreign Credits

Sonnenschein: IRS Issues Administrative Guidance on New Reporting and Withholding Rules for Cross-Border Payments

Mayer Brown: Significant Revisions to US International Tax Rules

Foreign Account Tax Compliance Act of 2009 (FATCA)

Sutherland: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

Latham & Watkins: Preparing for FATCA Compliance: The First Step

SJBerwin: Jumping on the FATCA Bandwagon

Codification of Economic Substance Doctrine

Alston & Bird: Supreme Court to Review Economic Substance Case [United States v. Gary Woods]

Alston + Bird: IRS May Apply Economic Substance Doctrine to Securities Lending Transactions Entered to Avoid U.S. Withholding Tax

Alston + Bird: Economic Substance Doctrine Defense Plan

Cancellation of Debt Income (CODI)

Dechert: Treatment of Excess Nonrecourse Partnership Debt and COD Income Under Section 108

Jones Day: Partial Debt Cancellations: Slicing Debt with Occam's Razor

Clifford Chance: The IRS Releases Temporary Regulations Regarding the Election to Defer Cancellation of Debt Income

Obama Administration's FY2011 Budget & Greenbook

ReedSmith: Significant Tax Changes Included in the Administration’s Fiscal Year 2011 Budget Proposal

Vinson & Elkins: Proposed Repeal of Fossil Fuel Tax Preferences

McDermott Will & Emery: Key Energy-Related Tax Provisions in the 2011 Budget Proposal

Obama Administration's FY2010 Budget & Greenbook

Alston + Bird: Joint Committee on Taxation Analyzes Administration’s Transfer Pricing Proposals and Suggests Three Additional Changes

K+L Gates: Impact of President's Proposals on Individuals

Morrison & Foerster: Administration Issues General Explanation of its Fiscal Year 2010 Revenue Proposals, Including Provisions Affecting Individuals