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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
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
