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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

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

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 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

Final Regulations under section 871(m) clarify withholding tax rules for equity-linked derivatives, yet many challenges remain
  • Shearman & Sterling LLP
  • USA
  • October 13 2015

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section

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

After a series of high-profile data breaches at both financial and nonfinancial companies, regulators are increasingly highlighting the need for

IRS identifies certain basket derivatives as reportable transactions
  • Vedder Price PC
  • USA
  • September 23 2015

On July 8, 2015, the Internal Revenue Service (the "IRS") identified as reportable transactions certain derivative contracts that reference a basket

Comeback victory: the IRS issues final dividend equivalent regulations
  • Mayer Brown LLP
  • USA
  • September 21 2015

Chuck Tanner, the unsinkable manager of the Pittsburgh Pirates baseball team, said he had three secrets to managing the 1979 World Series

Withholding tax on dividend equivalent payments
  • Sullivan & Cromwell LLP
  • USA
  • September 21 2015

On September 18, 2015, the Treasury Department and the IRS published final and temporary and Proposed regulations (the “Final Regulations” and