AGG Talks: Cross-Border Business Podcast - Episode 19: The Rise of Korean Investment in the Southeast U.S.
Public M&A Day in Frankfurt
Fintech Focus Podcast | Are Regulators Dictating Fintech Deal Terms?
Business Better Podcast Episode: Strategic Partnership and Company-Building Investments – A Conversation with Prairie Capital
JONES DAY TALKS®: Corporate Venture Capital: Market Overview, Trends in Deal Terms, and Special Considerations
Business Better Podcast Episode: Investing in the New Mainstream Economy - A Conversation with Palladium Equity Partners
Healthcare Investments: Analyzing the Surge in Infusion Centers
Electricity Markets: A Regional Perspective
PODCAST: Williams Mullen's Benefits Companion - Exploring the Value of Qualified Default Investment Alternatives
Hot Topic: UPMIFA in the Context of Financial System Instability
5 Key Takeaways | The U.S. Investment in Clean Energy and the Potential for Supply Chain Snags
Consumer Finance Monitor Podcast Episode: A Primer on “Dark Patterns,” with Special Guest Andrew Nigrinis, PhD, Managing Principal, Edgeworth Economics
Stoel Rives | Deeply Rooted Podcast S2E4: S2E4: Skye Root, Founder of Root Agricultural Advisory
Legal Alert | DOL Opens ESG Door: What Does It Mean for Plan Fiduciaries?
Nota Bene Episode 27: The Gangbuster State of Private Equity and Merger and Acquisition Cycles in the U.S. with Luca Salvi
Value-based health care: private equity investors
Health care M&A
In August 2022, the United States (U.S.) Congress passed the Inflation Reduction Act of 2022 (the “IRA”), landmark legislation that modified and extended the longstanding 30% investment tax credit (ITC) for solar photovoltaic...more
The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits. In our last update, we discussed how the emerging market for tax insurance may provide comfort to prospective...more
Since 1916, Congress has exempted from income taxation clubs formed to facilitate social interaction between its members. As a result, country clubs, hunting and fishing clubs, college sororities and fraternities, and...more
Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more
On March 5, 2024, the IRS issued final regulations under Internal Revenue Code Section 6417 (the “Final Regulations”) with respect to energy tax credits which are directly payable to State and local governmental entities as...more
In a previous article, we introduced the fundamental concepts of the yield restriction and rebate rules set out in the Internal Revenue Code and Treasury Regulations and how tax-exempt bonds may be affected by high interest...more
On April 2, 2024, the U.S. Department of Labor (DOL) announced its final amendment to prohibited transaction class exemption 84-14 (the QPAM Exemption). The QPAM Exemption is a broad-based class exemption relied upon by many...more
Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more
On November 22, 2023, the Internal Revenue Service and Treasury Department released proposed regulations (the Proposed Regulations) relating to the investment tax credit (the ITC) under Section 48 of the Internal Revenue Code...more
Since the enactment of the statutory donor-advised fund (“DAF”) rules under the Pension Protection Act of 2006, sponsoring organizations that manage DAF programs have relied on the Internal Revenue Code (“IRC” or the “Code”)...more
Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more
In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more
Real estate developers have long had ample reasons to take on projects involving historic buildings, courtesy of Section 47 of the Internal Revenue Code of 1986. As amended, Section 47 (the “Code”) provides for a...more
Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more
The application cycle for the first round of credits will soon open. Treasury’s additional guidance clarifies what types of facilities may qualify for credits, the submission process and the selection criteria for evaluating...more
The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more
When it comes to the taxation of stock options, the Internal Revenue Code (Code) does not define capital assets. Rather, it identifies those assets that are not capital assets. ...more
Structuring a family’s investment activities can be complex. Across assets, activities, relationships and the particular circumstances of each family member-investor, a family office will typically provide a spectrum of...more
On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more
Both the Internal Revenue Code (Code) and the Employee Retirement Income Security Act of 1974 (ERISA) include prohibited transaction provisions that literally prohibit certain transactions (unless exempted by statute or by a...more
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more
Perhaps you are tired of reading that I grew up in the Panama Canal Zone, but it is one of the last bastions of American colonialism. Personally, I do not like the word “colonialism” because it inevitably conjures up negative...more
Cryptocurrency holders often want to put their assets into an entity for a host of reasons, such as asset protection, arranging negotiated management rights and exit planning. This post discusses basic federal income tax...more
The industry will have two years to learn the new requirements and develop systems to ensure compliance. On November 15, 2021, President Biden signed the US$1.2 trillion Infrastructure Investment and Jobs Act into law...more