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Ways and Means Committee issues draft provisions to reform taxation of financial instruments
- Greenberg Traurig LLP
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- USA
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- January 25 2013
On January 24, 2013, the Chairman of the House Ways and Means Committee (the "Committee") released a Tax Reform Proposal on Financial Instruments
IRS issues new regulations on dividend withholding
- Greenberg Traurig LLP
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- USA
- -
- January 25 2012
On January 19, 2012, the Internal Revenue Service released two sets of regulations addressing the U.S. withholding tax rules for dividend equivalents paid on certain derivatives
Et Tu Babe: new U.S. tax regulations change the landscape for dividend equivalents
- Greenberg Traurig LLP
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- USA
- -
- January 23 2012
In Et Tu Babe, Mark Leyner's forward-looking hyperactive take on 1990s popular culture, the author created a complex and absurdist multi-dimensional view of each situation in which he placed his characters and, frequently, himself
Derivatives IRS issues technical advice memorandum on commodities hedges
- Greenberg Traurig LLP
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- USA
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- November 16 2011
The Internal Revenue Service (IRS) released a Technical Advice Memorandum (TAM) relating to hedges and exchanges on commodities contracts
Difficulty in every opportunity: TAM 201142020 provides insights on deemed exchanges and hedging
- Greenberg Traurig LLP
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- USA
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- November 9 2011
When my children were small, I mischievously told them that I studied federal income tax law at Harry Potter’s Hogwarts Academy
Sometimes a vague notion: the IRS proposes to update the tax rules for swaps and futures
- Greenberg Traurig LLP
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- USA
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- September 22 2011
Jay McInerney's 1980s classic novella, Bright LightsBig City, about starting a career in New York City in the fact-checking department of a major (and perhaps selfimportant) magazine, resonated with us as we began our careers writing memos on tax issues at major New York law firms
Closer to fine: IRS expands the safe-harbor for swap assignments to accommodate Dodd-Frank implementation
- Greenberg Traurig LLP
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- USA
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- July 22 2011
On July 21, 2011, the Internal Revenue Service (IRS) promulgated a temporary regulation providing very good news for users of derivative contracts
New IRS audit guidelines target equity swaps with non-U.S. counterparties
- Greenberg Traurig LLP
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- USA
- -
- January 20 2010
For over 20 years, applicable Treasury regulations have provided that income from an equity swap, including dividend equivalent payments, is foreign-source income in the hands of a non-U.S. person who did not enter into the swap in connection with the conduct of a United States trade or business
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- Workarea - Derivatives
- Workarea - Corporate Tax
- Firm Name - Greenberg Traurig LLP