The latest legal insights from Eversheds Sutherland.
Eversheds Sutherland and the DC LGBT Bar Association hosted a panel discussion on the recent wave of anti-LGBT legislative proposals across the country. The panel covered specific legislative proposals to limit the rights of LGBT individuals and advocacy efforts to prevent and challenge enactment. The panelists for this event were: Anya Marino, Clinical Instructor, LGBTQ+ Advocacy Clinic at Harvard Law School Casey Pick, Senior Fellow for Advocacy and Government Affairs at The Trevor Project Ryan Thoreson, Researcher in the Lesbian, Gay, Bisexual and Transgender Rights Program at Human Rights Watch This panel was co-sponsored by Eversheds Sutherland’s LGBT Affinity Group and the LGBT Bar Association for the District of Columbia. Eversheds Sutherland Associate Dennis Jansen serves as a co-Vice President of the DC LGBT Bar Association. Additional information and expanded panelist bios are available at the DC LGBT Bar Association website.
This two-hour webcast includes a judicial and litigation outlook for 2021, a review of state tax liabilities incurred by pass-through entities, as well as work from home issues for corporations and employees.
Please join Eversheds Sutherland M&A practitioners from around the world and Jinzy Zhu, M&A Legal Integration Lead Counsel at PayPal, for a 60-minute CLE accredited webinar on post-acquisition transaction integration. Post-acquisition transaction integration is the key to buy-side M&A success. We will be discussing and answering questions on a number of topics, including: Our top 5 tips to successfully complete post-acquisition transaction integration Developing and executing on the integration plan Legal entity consolidation and restructuring, governance and compliance Tax considerations for the combined operations Workforce and employee benefits Cybersecurity and data privacy Our top 5 post-acquisition transaction integration red flags
This program will examine the intersection of RegTech tools and anti-money laundering (AML) programs for institutions, including banks, cryptocurrency exchanges, securities exchanges, broker-dealers, and investment advisers. As institutions continue to leverage RegTech tools to enhance their AML programs, we discuss the impact of these RegTech tools on customer identification programs and know-your-customer compliance, as well as suspicious activity reporting filing requirements. How should institutions utilize these RegTech tools, and what is their responsibility to supervise them? What if something goes wrong, and how should institutions ensure proper guardrails exist when implementing RegTech tools into their AML programs? We will examine these questions, along with recent AML regulatory guidance, so that institutions are well positioned to understand the risks and rewards associated with these RegTech tools.
In June, the DOL released version 3.0 of its fiduciary proposal, which formally reinstated the investment advice fiduciary definition in effect since 1975 accompanied by new interpretations that extended its reach in the rollover setting, and proposed a new exemption for conflicted investment advice and principal transactions. This proposal would become part of the patchwork of fiduciary and best interest advice regulations that impact banks, broker-dealers, investment advisers, and insurance companies.Join Eversheds Sutherland attorneys Carol McClarnon, Mark Smith, Issa Hanna and Caitlin Naylor for a webcast on what financial institutions should be considering now in anticipation of adoption of DOL's proposal, taking into account the context of broader best interest developments.
All but three states have passed hate crimes laws, which generally provide harsher penalties for crimes motivated by a victim’s race, color, religion, national origin, sexual orientation, gender, gender identity, or disability. But how much do you know about how these laws work, who they protect, and why they’re an important tool in the fight against racism? The ACC Georgia Chapter welcomes Eversheds Sutherland's Amanda R. Giffin and John E. Sharpe to present in this engaging discussion.
The MSLP is designed for small and mid-size businesses that are unable to access the Paycheck Protection Program (PPP) or that require additional financial support after receiving a PPP loan. In general, eligible companies must have 15,000 or fewer employees or 2019 annual revenues of $5 billion or less. The Fed has committed to extending up to $600 billion of credit under the MSLP. The program, however, has come under some criticism from market participants and Capitol Hill for being too restrictive for businesses that want to borrow. While the Fed has made some changes to the initial terms set in April, and released the eligible lender application, as of today the MSLP is still not operational. SBIA members have expressed significant interest in the MSLP and how it might benefit their middle market companies.
While the current economic environment may force some companies and PE funds to divest assets or businesses, potential buyers will have the opportunity to make smart acquisitions. Cash-stable corporates and well-invested funds alike are already considering consolidation against the backdrop of an emerging ‘new normal’ and the need for some businesses to de-leverage. For businesses that have been adversely impacted by COVID-19, and for those looking to grow as we emerge from lockdown, we will discuss how to structure the deal terms to ensure getting fair value and closing certainty, including: Limited due diligence Uncertain title to assets Customer and vendor contract defaults Indemnification and rep and warranty insurance Closing conditions The interplay with insolvency proceedings
We will address market volatility, disruption of the supply chain, the impact of a reduced workforce and workforce management on maintaining business operations, reducing power prices and power price forecasts, and understanding and accessing governmental support packages. We will answer your questions in real time, including those about the impact on: supply chain disruption force majeure power purchase agreements financing and tax equity financing tax credits/safe harbor mergers and acquisitions downward pressures on oil prices Please submit your questions in advance as part of the registration process; there will also be the opportunity to submit questions live during the session. Speakers: JP Boutin | +44 292 047 8265 | Email Mark Dennison | +44 20 7919 0919 | Email Max Findeisen | +49 2 11 86 46 75 0 | Email Dorothy Franzoni | +1 404 853 8489 | Email Natascha Geraedts | +31 20 5600 692 | Email Amish Shah | +1 202 383 0456 | Email Madeleine Tan | +1 212 389 5006 | Email Iwan Walters | +97 14 38 97 02 8 | Email Tom Warren | +1 404 853 8548 | Email Jay Ze | +86 10 6583 7388 | Email
The last few years have seen a number of regulatory initiatives which will have a significant impact on annuity products. These initiatives are advancing by state insurance regulators as well as the SEC.In this Bottom Line videocast, Dodie Kent and Clifford Kirsch discuss: the continued emergence of registered index linked annuity products the NAIC’s amended Suitability Rule the SEC’s variable product summary prospectus and new disclosure regime rulemaking Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
This video is a discussion about the IFA USA Branch by its new president, Carol Tello, a partner in the Tax Practice Group at Eversheds Sutherland (US) LLP and Brian Tschosik, an associate in the Tax Practice Group.In this Bottom Line videocast, Carol Tello and Brian Tschosik discuss: Carol Tello’s election as the first woman president of the USA IFA Branch USA IFA, a 1,000 member organization, is one of approximately 68 national branches with a total of approximately 12,500 members worldwide The benefits of IFA membership Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Asset managers will need to consider how FinTech developments impact their business model in 2020, including developments related to digital asset securities, cryptocurrency-based ETFs and blockchain.In this Bottom Line videocast, Jamie Cain and Ben Marzouk discuss: blockchain use in the financial services and asset management industries custody issues related to digital asset securities automated FinTech solutions, including robo-advice and AML/KYC onboarding Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. Twice each year, Eversheds Sutherland releases a videocast analyzing recent results. In this Bottom Line videocast, Charles Capouet and Samantha Trencs discuss: the overall results for 2019, including a breakdown of corporate income tax and sales and use tax case results comparisons with the results from prior years significant Q4 2019 cases, including Matter of Mackenzie Hughes LLP v. New York State Tax Appeals Tribunal Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In 2020, state and local tax practitioners have witnessed the emergence of a new trend: the proposed taxation of advertising services and data usage. In this Bottom Line videocast, Charles Capouet and Samantha Trencs discuss: the proposed Maryland tax on gross revenues from digital advertising services potential expansions of the Nebraska and South Dakota sales taxes proposals for new taxes on data and data mining in New York and West Virginia Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Investor access to private funds is expanded under the SEC’s proposed rule amending the "accredited investor" definition.In this Bottom Line videocast, Michael Voynich and Nicholas Rinaldi discuss: the impact to Regulation D based on the proposal’s new categories of individuals and entities that would qualify as accredited investors how the exempt offering network operates today and how the definition seeks to harmonize the industry why the wealth analysis of natural persons should be only a starting point in determining who is an accredited investor Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Getting in the know. In this Bottom Line videocast, Michael Koffler and Bria Adams discuss Advisers Act regulatory developments, including: modernization of the Advisers Act Custody Rule SEC guidance on proxy voting responsibilities of advisers Global Investment Performance Standards (GIPS) 2020 Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
On February 19, 2020, the IRS issued two pieces of long-anticipated guidance on Section 45Q, Carbon Capture and Sequestration credits. In this Bottom Line videocast, Susan Lafferty and Amish Shah discuss: Section 45Q Carbon Capture and Sequestration credit Beginning of Construction Guidance—Notice 2020-12 Partnership Allocation Guidance—Revenue Procedure 2020-12 Expected future guidance Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In this Bottom Line videocast, Issa Hanna and Pooja Kohli discuss what to expect in 2020 on standard of conduct developments for broker-dealers and investment advisers, including: anticipated developments relating to the SEC’s Regulation Best Interest the paths forward for the proposed state fiduciary rules areas of enhanced regulatory focus under the Advisers Act Fiduciary Duty Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The SEC’s Division of Enforcement is likely to be active in 2020, investigating several issues important to broker-dealers and investment advisers.In this Bottom Line videocast, Brian Rubin and Adam Pollet discuss: cash sweeps and reverse churning retirement plans and 403(b) and 457 plans Regulation Best Interest Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Regulators are increasing pressure on financial institutions to demonstrate that they are proactively addressing the transition away from the London Interbank Offered Rate (LIBOR). The New York State Department of Financial Services’ request at the end of last year adds to the chorus of regulators concerned that insufficient preparations for the transition to alternative rates could have a negative impact on the safety and soundness of the financial markets generally and adversely affect the financial condition of individual financial institutions with LIBOR exposure.In this Bottom Line videocast, Jamie Cain and Lizet Steele discuss: financial institutions that are not already preparing for the transition away from LIBOR are feeling pressure from regulators to start doing so immediately regulators in the United States and abroad have requested that financial institutions submit LIBOR transition plans and/or indicate that the transition away from LIBOR will be an examination priority in 2020 while certain issues with respect to the transition are still being addressed and debated, standing by to await resolution of these issues is no longer a viable option for financial institutions with LIBOR exposure Since the recording of this videocast, the NYDFS has extended the deadline for submitting information regarding LIBOR transition plans to March 23, 2020. Discover more of the latest legal news and topics discussed by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Hear how proposed changes to the Advertising Rule and the Solicitation Rule under the Investment Advisers Act could affect private funds and their sponsors.In this Bottom Line videocast, Michael Koffler and Michael Voynich discuss: a brief history of the current rules and the proposed changes to the Advertising Rule and the Solicitation Rule the implications of those proposed changes the impact such changes will likely have, including on private funds, their sponsors and placement agents engaged by private funds Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Form ADV update season is now upon us, and as many investment advisers work toward the quickly approaching filing deadline, they will also have to grapple with a regulatory environment that is putting even more pressure on conflicts disclosure.In this Bottom Line videocast, Clifford Kirsch and Issa Hanna discuss: the SEC’s intense scrutiny of conflicts disclosure disclosure areas of focus for SEC examination and enforcement staff the interplay between Form ADV Part 2A and Form CRS Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
FINRA has identified several items in the SEC’s Regulation Best Interest (Reg BI) that it will examine for in the first half of 2020 as firms prepare for Reg BI compliance. In this Bottom Line videocast, Susan Krawczyk and Holly Smith discuss: FINRA’s 2020 Priorities Letter the nine items FINRA has targeted for Reg BI preparedness the emphasis on recommendation-related factors in preparing for Reg BI Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In 2020, investment companies should be prepared for important compliance deadlines and likely US Securities and Exchange Commission (SEC) rulemakings. In this Bottom Line videocast, Cynthia Beyea and Ronald Coenen Jr. discuss: upcoming compliance deadlines for the ETF rule and Form N-PORT likely final rulemakings in 2020 likely proposed rulemakings in 2020 Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Over the next year, the Department of Labor (DOL) will likely be issuing guidance in a number of areas that could impact asset managers and financial services companies. In this Bottom Line videocast, Carol McClarnon and Laura Taylor discuss: third time’s the charm – what the latest version of the DOL fiduciary rule could look like the impact of the end of 2019 SECURE Act and need for conforming regulations proxy voting regulations the missing "missing participant" guidance Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In this Bottom Line videocast, Meltem Kodaman and Lizet Steele forecast the Commodity Futures Trading Commission’s regulatory priorities of 2020, including: financial end-users will be phased in for purposes of the initial margin requirements for uncleared swaps finalizing position limits rules will be a top priority for the CFTC cross-border and post-trade name give-up proposals Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Dramatic changes are on the horizon for the most widely used benchmark for interest, investment and derivatives rates: the London Interbank Offered Rate (LIBOR). As a result, a broad swath of market participants, including lenders, borrowers, debt issuers, investors and derivatives counterparties are (or should be) evaluating the consequences of the potential cessation of LIBOR. This webcast discusses regulatory and industry efforts to prepare for the anticipated changes to LIBOR, focusing on US Dollar LIBOR, from the perspective of entities that are either or both borrowers and lenders, including business development companies (BDCs) and other private credit funds. The webcast will focus on: recent trends, developments and current timeline what issuers, lenders and borrowers should be doing to prepare for the cessation of LIBOR industry association and working group documentation solutions for legacy agreements and agreements going forward
Beginning June 2020, the SEC will require most broker-dealers and investment advisers to file and deliver a Form CRS to new, prospective and existing customers and clients. As firms begin to prepare Form CRS, much attention should be given to the delivery requirements.In this Bottom Line videocast, Holly Smith and Bria Adams discuss: quick facts about Form CRS how to deliver Form CRS when to deliver Form CRS steps to take when preparing to deliver Form CRS Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The SEC’s new Regulation Best Interest will require broker-dealers to make account recommendations in their customers’ best interest.In this Bottom Line videocast, Susan Krawczyk and John Walsh discuss: the standard in Regulation Best Interest governing account recommendations what types of account recommendations are covered what broker-dealers need to do to get ready for the new standard Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Firms that are dually-registered are subject to special considerations under the SEC’s new Regulation Best Interest when offering both advisory and brokerage accounts. In this Bottom Line videocast, Clifford Kirsch and Pooja Kohli discuss: the capacity disclosures a dual registrant must make what Form CRS should look like for dual registrants what dual registrants must consider when making account type recommendations Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel. Presenters: Clifford Kirsch | Email | +1.212.389.5052 Pooja Kohli, Litigation Specialist | Email | +1.212.389.5037
Recent SEC rulemaking and guidance heightened retail broker-dealer and investment adviser investment recommendation and advice standards and created certain compliance obligations with respect to account monitoring. Firms that provide account monitoring services should ensure their practices encompass recent developments.In this Bottom Line videocast, Michael Koffler and Nicholas Rinaldi discuss: broker-dealer account monitoring and recommendations under the solely incidental prong of the broker-dealer exclusion to the Advisers Act Regulation Best Interest’s impact on both implicit and explicit investment recommendations how an investment adviser may satisfy the duty of care when monitoring a client’s account Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The SEC’s new Regulation Best Interest imposes additional recordkeeping requirements on broker-dealers. These additional recordkeeping requirements will need to capture all information collected from and provided to retail customers in connection with Regulation Best Interest, and broker-dealers may need to build new or modify existing recordkeeping systems to capture all the required information.In this Bottom Line videocast, Eric Arnold and Ben Marzouk discuss: the SEC’s new Regulation Best Interest recordkeeping requirements and related retention periods how firms can leverage their existing records to satisfy the new requirements what new records firms will need to capture in order to comply with Regulation Best Interest Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The SEC’s new Regulation Best Interest will require broker-dealers to consider whether their existing investment platforms are designed to result in recommendations to retail customers that are in such customers’ best interests. In this Bottom Line videocast, Cliff Kirsch and Issa Hanna discuss: the changes that broker-dealer firms might have to make to their investment platforms in light of SEC Regulation Best Interest whether firms can continue to place limits on their investment platforms after the effective date of Regulation Best Interest how we expect SEC and FINRA examination and enforcement staff to approach the regulation of investment platforms after SEC Regulation Best Interest becomes effective Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In this Bottom Line videocast, Stefanie Wood and Brian Tschosik highlight the changes to US income tax treaties implemented by recently ratified treaty protocols between the United States and Luxembourg, Japan, Spain and Switzerland. Specifically, this videocast discusses the material provisions of the protocols, including: exchange of information provisions mandatory arbitration procedures updates to rates of withholding tax Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
On September 6, 2019, nearly concurrently with the issuance of proposed regulations under sections 451(b) and (c), the IRS and Treasury issued Rev. Proc. 2019-37, long-awaited administrative guidance regarding the new income recognition and advance payment rules. Since the TCJA’s changes to the historic income recognition and advance payment rules, taxpayers have been hopeful for administrative guidance to provide clarity regarding the implementation of the new rules. In this Bottom Line videocast, Ellen McElroy and Mike Resnick discuss: the automatic accounting method changes provided by Rev. Proc. 2019-37 critical aspects of the new guidance that taxpayers need to pay particular attention to in changing their applicable methods of accounting Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
On September 5, 2019, along with proposed regulations under section 451(b), the IRS and Treasury issued long-awaited proposed regulations under section 451(c). Since the TCJA’s addition of section 451(c) to the Code, taxpayers have been anticipating the arrival of proposed regulations to provide clarification and guidance needed to properly implement the new rules for advance payments. In this Bottom Line videocast, Ellen McElroy and Mike Resnick discuss: the new income deferral provision under section 451(c) a summary of the proposed regulations under section 451(c) critical aspects of the proposed regulations that taxpayers need to pay particular attention to in their implementation of the new rule Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
On September 5, 2019, along with proposed regulations under section 451(c), the IRS and Treasury issued long-awaited proposed regulations under section 451(b). Due to the significant changes to income recognition under section 451(b), taxpayers were hopeful the proposed regulations would provide them the clarification and guidance needed to properly implement the new income recognition standard. In this Bottom Line videocast, Ellen McElroy and Mike Resnick discuss: the new income recognition standard under section 451(b) a summary of the new proposed regulations under section 451(b) critical aspects of the new proposed regulations that taxpayers need to pay particular attention to in their implementation of the new standard Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Taxpayers may want to take advantage of the reopening of the Compliance Assurance Process (CAP) by the IRS Large Business and International Division (LB&I). Eligible companies can now apply for the popular program once again. In this Bottom Line videocast, Eversheds Sutherland attorneys Susan Seabrook and Daniel Strickland discuss: eligibility requirements application process overview pros and cons of participation for taxpayers Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The IRS recently released proposed regulations under section 861 that address digital transactions. This Bottom Line videocast discusses: the proposed expansion of the scope of existing Treas. Reg. § 1.861-18, which focuses on the classification of transactions involving computer programs, to apply to all transfers of "digital content"; the sourcing rules applicable to such transfers; and Prop. Treas. Reg. § 1.861-19, which provides guidelines for classifying cloud transactions as either services or as a lease. Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. In this Bottom Line videocast, Eversheds Sutherland attorneys Charles Capouet and Justin Brown discuss the results from the first two quarters of 2019, including: how taxpayers have fared in litigation in the first two quarters of 2019 compared to 2016, 2017 and 2018 three of the main cases from the second quarter of 2019: North Carolina Department of Revenue v. Kimberley Rice Kaestner, Franchise Tax Board of California v. Hyatt, and Department of Revenue v. Agilent Technologies, Inc. the recent Cook County Circuit Court decision, Mercury Sightseeing Boats, Inc. v. County of Cook, in which the court determined that the Department of Revenue violated the taxpayer’s procedural due process rights. Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In this Bottom Line videocast, Eversheds Sutherland’s Carol McClarnon and Laura Taylor discuss ERISA planning considerations for 2019, including: basic ERISA compliance Department of Labor regulatory examinations data privacy and cybersecurity considerations an ERISA litigation update Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In this bottom line videocast, Eversheds Sutherland’s Taylor Kiessig and Katie Sint* provide key takeaways from the proposed section 250 regulations, including: calculation of FDII and the section 250 deduction types of transactions that qualify documentation rules Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel. *Not admitted to practice. Application submitted to the District of Columbia Bar.
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. In this Bottom Line videocast, Charles Capouet and Chelsea Marmor share 2018 year-end observations, including: the overall results for 2018, including a breakdown of corporate income tax and sales and use tax case results comparative results from 2016-2018 significant Q4 2018 cases, including Canon Financial Services, Inc. v. Director, Division of Taxation Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Proposed regulations on foreign tax credits (FTCs) provide necessary guidance on how to characterize the stock of a controlled foreign corporation (CFC) for purposes of apportioning interest expense.This Bottom Line videocast discusses: the significance of CFC stock characterization for interest expense apportionment the proposed new framework for CFC stock characterization where does this leave you? Related content: Legal Alert: Allocation, apportionment and attribution, oh my – Proposed foreign tax credit regulations provide critical guidance Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
The November 26, 2018, release by the Internal Revenue Service of proposed regulations (REG-106089-18) related to IRC § 163(j) has provided some clarity for federal income taxpayers. But the regulations’ treatment of federal consolidated groups gives rise to complexities and questions as to how the limitation will operate at the state level.This Bottom Line videocast includes: an overview of IRC § 163(j) key elements of the proposed regulations important SALT considerations Related content Legal Alert: INXS? IRS issues proposed regulations under section 163(j) Legal Alert: Consolidated complexities – state corporate income tax implications of I.R.C. § 163(j) Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
Recently proposed regulations (REG-106089-18) provide needed guidance to the broadly applicable limitation on business interest expense under IRC § 163(j).This Bottom Line videocast includes key elements of the proposed regulations, such as: adoption of a broad definition of "interest" treatment of historic carryforwards and coordination rules clarification of the application of section 163(j) to consolidated groups, pass-through entities, non-US entities, and excepted trades or businesses Related content Legal Alert: INXS? IRS issues proposed regulations under section 163(j) Legal Alert: Proposed 163(j) regulations provide needed guidance to utilities Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel.
In October 2018, the Treasury released proposed regulations related to the Opportunity Zone program (sections 1400Z-1 and 1400Z-2), which was enacted to promote investments in certain low-income communities by providing investors tax incentives.This Bottom Line videocast discusses: the new opportunities provided by sections 1400Z-1 and 1400Z-2 tax incentives of the program, including gain deferral, reduction of gain amount and elimination of tax on post-acquisition appreciation the building blocks of the Opportunity Zone program
Blockchain and distributed-ledger technology hold tremendous promise, far beyond cryptocurrencies. However, there are also real pitfalls, which are often not identified until it is too late. This Bottom Line videocast discusses: What is blockchain, and how is it broader than bitcoin and other cryptocurrencies? Why it may be revolutionary, but why it will not solve all problems—and why it can create problems of its own. Why lawyers and boards must be involved early and often to stop the problems, design solutions and identify further opportunities. This is the third in a series of three Bottom Line videocasts discussing technology and innovation in the financial services industry.
Not much attention has been paid to the mechanics of the actual calculation of section 965 amounts. It is important to understand the mechanics of section 965 calculations and the inputs, especially in light of their impact on carry-over tax attributes in future years.This Bottom Line videocast discusses: a brief summary of section 965 the calculation of the section 965(c) deduction using Worksheet 1.1 in Publication 5292 under two scenarios the calculation of the disallowed foreign tax credit using Worksheet H in Publication 5292 under the scenarios
Regulators are grappling to define cryptoassets and are applying existing regulations or contemplating new rules to oversee markets for these new asset class(es). In this Bottom Line videocast, Eversheds Sutherland (US) Partner Greg Kaufman and Eversheds Sutherland (International) Partner Andrew Henderson discuss: important jurisdictional and definitional issues before US courts the UK Financial Conduct Authority’s facilitation and regulation of blockchain technology and cryptoassets
Significant profits are being generated by the "digital economy" while revenue authorities question the ability of traditional physical presence-based tax rules to properly capture earnings. In this Bottom Line videocast, Eversheds Sutherland (US) Partner Susan Seabrook and Eversheds Sutherland (International) Partner Ben Jones discuss: Perceived BEPS risk High-profile examples of digital businesses using low tax jurisdictions Modernization—how? Solutions being considered
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