The Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) on April 4, 2016 released proposed regulations under Section 385 of the Internal Revenue Code tha...
Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends for withholding tax purposes. On December 4, 2013, the Treasury D...
The tax provisions commonly referred to as “FATCA” use a 30% withholding tax to enforce a worldwide reporting regime designed to prevent U.S. persons from using offshore accounts to e...
Treasury has issued proposed regulations interpreting the segment of the Internal Revenue Code commonly referred to as “FATCA.” These proposed regulations would take a number of impor...
Section 871(m) of the Internal Revenue Code, enacted in 2010, imposes withholding tax on, among other things, “dividend equivalents” paid to foreign counterparties pursuant to “spec...
On November 2, 2011, Treasury released proposed revisions to the regulations under Section 892 of the Internal Revenue Code of 1986 (the “Code”). Section 892 provides an exemption fro...
On July 22, the Tax Court published its decision in the case of Anschutz Company v. Commissioner, involving a taxpayer that (indirectly) engaged in various prepaid variable forward contra...
Today the House passed H.R. 4213, “American Jobs and Closing Tax Loopholes Act of 2010.” The bill contains both new proposals and proposals that were included in the Administration’...
This morning, the Obama Administration provided more detail on its previously announced plan to reform the U.S. tax laws relating to the taxation of income earned by foreign subsidiaries ...
As has been widely discussed in the financial press, on July 28, 2008, Treasury Secretary Henry Paulson announced the Treasury Department’s support for covered bonds as “a promising f...
