Tax

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Current Tax Structuring Techniques for Private Equity Funds

Los Angeles associate Afshin Beyzaee is the author of "Current Tax Structuring Techniques for Private Equity Funds" [PDF] published in the May/June 2007 issue of the Journal of Taxation and Regulation of Financial Institutions.© 2007 Civic Research Institute.  This article originally appeared in Journal of Taxation and Regulation of Financial Institutions and is reproduced here with permission.  For information on the journal, visit http://www.civicresearchinstitute.com/tfi.html.

Client Alert | June 1, 2007

Nine Action Steps to Implement the Section 409A Deferred Compensation Regulations Before the Deadline of December 31, 2007

On April 10, the IRS issued final regulations interpreting the rules and standards under Section 409A of the Internal Revenue Code ("Section 409A").  Our client memorandum of April 11 summarizes key provisions of the regulations.  Section 409A provides various rules that "deferred compensation" must satisfy in order to avoid unfavorable tax treatment of employees, directors and other service providers, including immediate income tax, a 20% penalty tax, and an interest charge.  In addition, some states (including California) have implemented similar rules, and deferred compensation payments that do not comply with Section 409A can be taxed at marginal rates exceeding 75%.The sweep of Section 409A is extremely broad, and reaches far beyond traditional nonqu

Client Alert | April 26, 2007

IRS Releases Final Regulations Interpreting the Code Section 415 Limits on Benefits Under Tax-Qualified Retirement Plans

On April 5, the IRS issued final regulations under Section 415 of the Internal Revenue Code (“Code”). Section 415(c) of the Code generally limits the amount of annual contributions to a tax-qualified defined contribution plan on behalf of a participant to the lesser of 100% of compensation or $40,000 (adjusted for inflation; currently $45,000).

Client Alert | April 16, 2007

IRS Releases Final Section 409A Regulations on Deferred Compensation

On April 10, the IRS issued long-awaited and often-delayed final regulations ("Regulations") interpreting the deferred compensation rules under Section 409A of the Internal Revenue Code ("Section 409A").

Client Alert | April 11, 2007

February 28 Deadline to Take Advantage of IRS Settlement Program for Stock Options and SARs Subject to Section 409A That Were Exercised in 2006

On February 8, the IRS Released Announcement 2007-18. Pursuant to the Announcement, employers may take advantage of a special settlement program (the "Program") to address the payment of additional taxes arising under Section 409A of the Internal Revenue Code as a result of an employee's exercise of a "discount" stock option or stock appreciation right in 2006.

Client Alert | February 9, 2007

A Reit Map: The regional idiosyncrasies of real estate investment trusts

London partner Nicholas Aleksander, Los Angeles partner Dhiya El-Saden, Paris partner Ariel Harroch, Munich partner Hans Martin Schmid and of counsel Christian Schmidt are the authors of "A Reit Map: The Regional Idiosyncrasies of Real Estate Investment Trusts" [PDF] published in the February 2007 issue of the International Financial Law Review.

Client Alert | February 1, 2007

News Analysis: Does Denkavit Signal the End of Withholding Tax?

Paris associate Jérôme Delaurière is the author of "News Analysis: Does Denkavit Signal the End of Withholding Tax?" [PDF] published in the January 29, 2007 issue of  Tax Analysts's Tax Notes International (pg 303).

Client Alert | January 29, 2007

Senate Finance Committee Proposals Would Impact Deferred Compensation

On January 17, the Senate Finance Committee unanimously approved the Small Business and Work Opportunity Act of 2007 (the "Act"). The Act includes a number of tax breaks for small businesses in connection with the proposed increase in the minimum wage.

Client Alert | January 18, 2007

2006 Employee Benefits Deadlines Require Immediate Attention

As another year comes to a close, employers must take a number of actions to (i) address Section 409A of the Internal Revenue Code, (ii) amend their tax-qualified retirement plans to reflect certain rules that became effective in 2006, and (iii) begin operating their plans in compliance with new rules that become effective on January 1, 2007.

Client Alert | December 7, 2006

Real Estate Private Equity – Taxation for Foreign Investors

Munich partner Hans Martin Schmid and of counsel Christian Schmidt are the authors of "Real Estate Private Equity - Taxation for Foreign Investors" [PDF] published in the 2006 Private Equity Financial Yearbook.

Client Alert | December 1, 2006

IRS Extends Section 409A Transition Relief Through December 31, 2007

On October 4, the IRS issued long-expected guidance extending the transition relief under Section 409A of the Internal Revenue Code (the "Code"). As described below, subject to an exception for certain "in the money" stock options granted to Section 16 officers and directors of publicly-traded companies, Notice 2006-79 generally extends the key transition rules through December 31, 2007.Effective Date/Good Faith Reliance.

Client Alert | October 5, 2006

Major Pension Legislation Enacted

The Congress has passed major pension legislation, the "Pension Protection Act of 2006" (the "Act"), which President Bush has promised to sign into law.  We describe below some of the most important changes the Act makes and attach a detailed chart [PDF] summarizing many of the key benefits provisions of the Act.  In addition, a Gibson Dunn update is available on certain changes affecting investment funds.Funding of Defined Benefit Plans.  The Act significantly changes the defined benefit plan funding rules, generally effective for plan years beginning in 2008.  Plan sponsors may want to discuss these changes with their actuaries and consider whether additional contributions should be made before 2008.  In particular, plans that are “at risk

Client Alert | August 8, 2006

Delaware im Wettstreit mit Luxemburg

Munich Partner Jeffrey M. Trinklein and Associate Christian Schmidt are the authors of "Delaware im Wettstreit mit Luxemburg" [PDF in German] in the February 1, 2006 issue of the newspaper Börsen-Zeitung.

Article | February 1, 2006