We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 988

Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime
  • Proskauer Rose LLP
  • USA
  • February 5 2016

Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section


New Year: New Regulatory Developments Affecting Managers of Hedge Funds, Private Equity Funds and Other Private Funds
  • Proskauer Rose LLP
  • OECD, USA
  • January 25 2016

Regulators were busy at the end of 2015, especially in the United States, perhaps being motivated to push forward new rule proposals in anticipation


Corporate & Regulatory Compliance: Are You Asking the Right Questions?
  • Greenberg Traurig LLP
  • USA
  • January 21 2016

Due to regulatory changes made in response to the financial crisis of 2008, market participants entering into over-the-counter derivative


The Trade Date Rule
  • Greenberg Traurig LLP
  • USA
  • December 9 2015

The tax law is like, well, death and taxes - you can run from it, but you cannot hide. This time of year, as buy-side funds, insurance companies, and


Foreign Banks, U.S. Branches, and Equity Swaps
  • Greenberg Traurig LLP
  • USA
  • December 9 2015

When foreign banks doing business in the U.S. calculate gain or loss from equity swaps, they would do well to pay attention to common law doctrines


Allocating Section 871(m) withholding tax risk: ISDA publishes new protocol addressing withholding under Section 871(m)
  • Sutherland Asbill & Brennan LLP
  • USA
  • November 16 2015

On November 2, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2015 Section 871(m) Protocol (the Protocol) that


871(m) re-redux
  • Greenberg Traurig LLP
  • USA
  • November 5 2015

Time was not long ago, paying tax on U.S. source dividends was optional for offshore investment funds. It was easy for funds to avoid withholding


US withholding tax on dividend equivalent payments under swaps
  • Katten Muchin Rosenman LLP
  • USA
  • October 16 2015

The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on


IRS finalizes regulations governing withholding on dividend equivalent payments
  • Allen & Overy LLP
  • USA
  • October 16 2015

On September 17, 2015, the U.S. Internal Revenue Service (the IRS) issued final regulations under Section 871(m) of the U.S. Internal Revenue Code of


IRS delays effective date for new regulations on embedded loans in swaps
  • Morgan Lewis & Bockius LLP
  • USA
  • October 14 2015

The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as