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Immediate clampdown on debt buy-backs

Jones Day
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USA
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October 31 2009

The Government have announced in a Written Ministerial Statement that changes will be made in next year's Finance Bill, with effect from 14 October 2009, to amend the UK tax rules applying where existing debt is purchased at a discount by a company connected to the debtor

Treasury issues proposed regulations for foreign sovereign investors under Section 892

Jones Day
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USA
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November 29 2011

This White Paper analyzes the proposed regulations recently issued by the Department of the Treasury and the Internal Revenue Service under 892 of the Internal Revenue Code, the provision of the Code that exempts from federal income tax certain investment income of "foreign governments"

Treasury issues proposed regulations on the information reporting and withholding tax provisions of FATCA

Jones Day
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USA
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April 18 2012

On February 8, 2012, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released proposed regulations (the “Proposed Regulations”) implementing the Foreign Account Tax Compliance Act (“FATCA”) provisions of the Hiring Incentives to Restore Employment Act enacted on March 18, 2010 (“HIRE”

The FATCA protocol: to adhere or not to adhere?

Jones Day
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USA
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September 6 2012

On August 15, 2012, the International Swaps and Derivatives Association ("ISDA") released a new Protocol relating to the effect on ISDA derivatives of taxes levied by the United States under the Foreign Account Tax Compliance Act ("FATCA"

Major tax incentive for bank purchases: IRS eliminates the limitation on banks' built-in losses post-purchase

Jones Day
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USA
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October 8 2008

On September 30, the IRS issued a notice that creates a major tax incentive for buying or making major investments in banks

EuroResource--deals and debt

Jones Day
-
Argentina, Cyprus, France, United Kingdom, USA
-
April 29 2013

On 29 March 2013, the Republic of Argentina proposed an alternative payment formula to the U.S. Court of Appeals for the Second Circuit that, if

Search results

Immediate clampdown on debt buy-backs

Treasury issues proposed regulations for foreign sovereign investors under Section 892

Treasury issues proposed regulations on the information reporting and withholding tax provisions of FATCA

The FATCA protocol: to adhere or not to adhere?

Major tax incentive for bank purchases: IRS eliminates the limitation on banks' built-in losses post-purchase

EuroResource--deals and debt

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