U.S. tax authorities issue final FATCA regulations *

USA - January 25 2013
On January 17, 2013, the U.S. Department of the Treasury (Treasury Department) and U.S. Internal Revenue Service (IRS) issued final Treasury…

Co-authors: Jamiel E. Poindexter, Amanda H Nussbaum, Martin T Hamilton, Mary B Kuusisto, Scott S Jones.

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ISDA publishes 2012 FATCA Protocol *

USA - August 28 2012
On August 15, 2012, the International Swaps and Derivatives Association (the "ISDA") opened the ISDA 2012 FATCA Protocol (the "FATCA Protocol") for adherence.

Co-authors: Amanda H Nussbaum, Martin T Hamilton, Charles W Stones.

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Deductibility of charitable contributions to LLCs wholly owned by charitable organizations *

USA - August 9 2012
On July 31, 2012, the Internal Revenue Service (the IRS) issued Notice 2012-52 (the Notice), providing long awaited confirmation that a charitable contribution to a limited liability company that is wholly owned by a charitable organization, and classified as a disregarded entity for U.S. federal income tax purposes (an SMLLC), will be treated as a contribution to a branch or division of the charitable organization.

Co-authors: Elizabeth M. Mills, Jacob I. Friedman, Gary Silber, Amanda H Nussbaum.

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IRS and Treasury Department publish anticipated FATCA guidance *

USA - February 9 2012
Proposed Regulations under the Foreign Account Tax Compliance Act Issued February 8, 2012.

Co-authors: Jamiel E. Poindexter, Amanda H Nussbaum, Arnold P May, Mary B Kuusisto, Scott S Jones.

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IRS and Treasury Department publish anticipated guidance on "dividend equivalent" payments derived from equity swap arrangements *

USA - January 27 2012
On January 19, 2012, the U.S Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued rules governing when equity swaps and similar transactions would result in imposition of U.S. withholding tax under Section 871(m) and related Sections of the Internal Revenue Code of 1986, as amended (the "Code").

Co-authors: Michael Fernhoff, Amy G. Drais, Amanda H Nussbaum, Arnold P May, Martin T Hamilton.

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