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...
On March 18, President Obama signed the Hiring Incentives to Restore Employment Act (the “Act”). The Act includes a version of the “Foreign Account Tax Compliance Act,” a provisio...
Fill in the blank: “The last 18 months have been a time of testing for ____.” Your answer says a lot about you: “Those who lost their jobs” shows your compassion; “the economy,?...
President Barack Obama unveiled plans to propose a financial crisis responsibility tax that would be levied on the largest financial institutions in terms of assets for at least the next ...
The long awaited public-private investment program announced by Secretary Geithner on March 23, 2009 contains two key components: a securities purchase program, designed to remedy the ill...
