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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

Financial services
  • Squire Patton Boggs
  • USA
  • July 28 2014

On Thursday, July 31, the Government Accountability Office (GAO) is expected to release a long awaited report on funding advantages of the largest

Congress scrutinizes hedge funds’ use of financial derivatives
  • Sutherland Asbill & Brennan LLP
  • USA
  • July 25 2014

This week the Senate Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs (Subcommittee), in conjunction

International regulatory update 12 16 May 2014
  • Clifford Chance LLP
  • Japan, Luxembourg, United Kingdom, USA, Belgium, China, European Union, Hong Kong
  • May 19 2014

The EU Council has formally approved the proposals for a directive on markets in financial instruments repealing Directive 200439EC (MiFID 2) and a

Investment management newsletter - Spring 2014
  • Kaye Scholer LLP
  • Germany, United Kingdom, USA
  • May 7 2014

At the end of 2013, the US Securities and Exchange Commission implemented changes to Rule 506 under Regulation D (Regulation D) promulgated under