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ABCs of cross-border derivatives
  • Cadwalader Wickersham & Taft LLP
  • USA
  • June 26 2015

This outline examines the U.S. tax consequences produced by derivative instruments in international financing transactions and highlights the

Distinguishing between captive insurance and related party derivatives: Chief Counsel Advice memorandum 201511021
  • McDermott Will & Emery
  • USA
  • June 23 2015

In Chief Counsel Advice (CCA) memorandum 201511021, the Internal Revenue Service (IRS) considered whether a contractual arrangement transferring

Hedge fund report - summary of key developments - spring 2015
  • Paul Hastings LLP
  • USA
  • June 1 2015

This continues to be a time of rapid change for the hedge fund industry, as the Securities and Exchange Commission (the "SEC"), the Commodity Futures

Funds talk: June 2015
  • Kramer Levin Naftalis & Frankel LLP
  • USA
  • June 1 2015

When the International Swaps and Derivatives Association (ISDA) released the 2014 Resolution Stay Protocol, it marked a seismic shift in the rules

New temporary and proposed regulations offer welcome clarification on application of the embedded loan rule
  • Sutherland Asbill & Brennan LLP
  • USA
  • May 13 2015

On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC 446 and 956 (T.D

Temporary regulations modify treatment of nonperiodic payments made or received pursuant to notional principal contracts
  • Sidley Austin LLP
  • USA
  • May 8 2015

On May 8, 2015, the Treasury Department and the Internal Revenue Service (IRS) published final and temporary regulations (the "Temporary

Recent developments concerning US Tax Code Section 871(m) dividend equivalent rules
  • Mayer Brown LLP
  • USA
  • February 2 2015

Two developments may be converging in a way that will result in delayed effective dates for US final dividend equivalent regulations. And, while

Expect focus - volume III, Summer 2014
  • Carlton Fields Jorden Burt
  • USA
  • September 16 2014

EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and

Financial services update September 15 2014 judicial developments
  • Winston & Strawn LLP
  • USA
  • September 15 2014

Dow and several foreign banks created partnerships that generated over one billion dollars in tax deductions for Dow. The partnerships allocated the

Local law shopping through “derivative benefits”
  • Bilzin Sumberg Baena Price & Axelrod LLP
  • USA
  • August 8 2014

Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on