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ISDA 2010 HIRE Act protocol

  • Morrison & Foerster LLP
  • -
  • Global, USA
  • -
  • October 13 2010

As discussed in more detail in a prior issue of MoFo Tax Talk, the HIRE Act treats as a U.S.-source dividend any “dividend equivalent” for purposes of U.S. withholding tax provisions

Senator Ron Wyden’s “Oil Bill”

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 2 2009

On August 6, 2009, Senator Ron Wyden (D-Oregon) introduced the "Stop Tax-breaks for Oil Profiteering Act" in the Senate, which is intended to temporarily curb excessive speculative trading in the oil and gas futures markets by eliminating the preferential tax treatment of direct and certain derivative interests in oil and natural gas

IRS issues Industry Director Directive on Total Return Swaps

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 31 2010

On January 14, 2010, the IRS issued an Industry Director Directive on Total Return Swaps Used to Avoid Dividend Withholding Tax ("IDD"