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New U.S. tax regulations provide “non-recognition” treatment for nonassigning counterparty on transferred or assigned derivatives

  • Sidley Austin LLP
  • -
  • USA
  • -
  • July 25 2011

The U.S. Department of Treasury has issued temporary and proposed regulations (the “New Regulations”) addressing whether there is a deemed exchange (resulting in a taxable event) by the nonassigning counterparty (i.e., the remaining party) when the other counterparty assigns or transfers its interest in certain derivative contracts

Tax implications of new ISDA 2010 HIRE Act protocol for equity swap participants

  • Sidley Austin LLP
  • -
  • USA
  • -
  • September 9 2010

A new ISDA Protocol (the "Protocol"), primarily concerning equity swaps, was released on August 23, 2010

IRS releases audit guidelines on equity swaps

  • Sidley Austin LLP
  • -
  • USA
  • -
  • February 10 2010

On January 14, 2010, the IRS released an industry directive alerting its field offices that non-U.S. persons may be using abusive total return swaps to avoid U.S. withholding tax on dividends