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IRS Proposes Regulations Under Section 892 Regarding Taxation Of Foreign Government Entities
The Internal Revenue Service (IRS) has issued proposed regulations under Section 892 of the Internal Revenue Code (available here) that generally provide favorable clarifications and modifications of the rules governing eligibility for the Section 892 tax exemption of a controlled entity of a...
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The IRS Proposes New Rules Under Section 892 That May Simplify Foreign Governments’ Investments In The United States, Including In Private Equity Funds
On November 2, 2011, the Internal Revenue Service (the “IRS”) issued proposed regulations under section 892[1] (the “Proposed Regulations”) that provide guidance to foreign governments and their controlled entities for making investments in the U.S. The Proposed...
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Delaware Award Guides Special Committees On Controlling Stockholder Transactions
On October 14, 2011 Chancellor Leo Strine of the Delaware Court of Chancery awarded $1.263 billion to Southern Peru Copper Corp. ("Southern Peru") following trial of a derivative lawsuit against a controlling stockholder of Southern Peru and certain of its affiliates who served as...
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