- As a result of additional regulatory requirements, merger and acquisition discussions and activity are increasing in the banking industry. Associated transaction costs incurred related to a merger or acquisition transaction can be significant. These costs can include fees for financial advice, legal services, due diligence services, and expenses to arrange debt financing and can greatly impact a company’s financial statement.
- Jim Alajbegu, Baker Tilly International Tax Firm Leader, discusses tax inversions with Chitra Nawbatt, anchor and correspondent for CTV News.
- In the recently published Revenue Ruling 2014-18, the Internal Revenue Service (IRS) concluded that certain nonqualified stock options (NSOs) or stock appreciation rights (SARs) would not be subject to the anti-deferral rules of Internal Revenue Code section 457A (section 457A). Generally, section 457A prohibits the deferral of income for service providers that perform services for nonqualified entities (i.e., foreign corporations based in offshore tax havens, entities substantially owned by tax-exempt organizations, or other tax-indifferent parties).
- In June 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued an addendum to the “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure”.
- Recently, project sponsors have combined New Markets Tax Credits with EB-5 financing in order to strengthen the overall financing structure of the projects. While significant benefits can be achieved, several structuring challenges need to be overcome.
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