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A new innovation on the IPO landscape has emerged in the last two decades, allowing owner-founders to extract billions of dollars from newly-public companies. These IPOs — labeled supercharged IPOs — have been the subject of widespread debate and controversy: lawyers, financial experts,...
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The Treasury Department should issue regulations treating the allocation and distribution of partnership profits in private equity funds — carried interest — as payments for services. My suggested “tax arbitrage” approach uses the presence of tax-exempt limited partners in the investment...
Persistent link: https://www.econbiz.de/10013015289
In Tax Legislation in the Contemporary U.S. Congress, Michael Doran describes an equilibrium of gridlock punctuated by the occasional passage of strikingly clean, non-particularistic legislation. This Commentary explores how the mundane, unseemly, and largely unnoticed legislative ritual of...
Persistent link: https://www.econbiz.de/10013054459
The purpose of this brief is to correct and respond to two arguments in Petitioner-Appellee Altera's petition for rehearing en banc and briefs of amici supporting the petition for rehearing. First, Treasury's regulation requiring cost sharing of stock-based compensation and the Ninth Circuit...
Persistent link: https://www.econbiz.de/10012863203
Most of us share a vague intuition that the rich, sophisticated, well-advised, and politically connected somehow game the system to avoid regulatory burdens the rest of us comply with. The intuition is correct; this Article explains how it’s done. Regulatory gamesmanship typically relies on a...
Persistent link: https://www.econbiz.de/10014197170
Pigouvian (or "corrective") taxes have been proposed or enacted on dozens of products and activities that may be harmful in excess: carbon, gasoline, fat, sugar, guns, cigarettes, alcohol, traffic, zoning, executive pay, and financial transactions, among others. Academics of all political...
Persistent link: https://www.econbiz.de/10014147326
Amici file this brief to provide the Ninth Circuit with relevant background information on the basics of transfer pricing and cost-sharing agreements, and to advance four key points. First, the 2003 cost-sharing regulation at issue in this case is substantively reasonable under the...
Persistent link: https://www.econbiz.de/10014034904
This amicus curiae brief in Altera Corporation v. Commissioner supports the government's position and the view of the majority in a 9th Circuit opinion issued on July 24, 2018 and later withdrawn. Amici are tax law professors who conclude that the stock-based compensation cost sharing...
Persistent link: https://www.econbiz.de/10014111013