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Senator Wyden Proposes New Regime for Taxation of Derivatives
  • Steptoe & Johnson LLP
  • USA
  • May 19 2016

On May 18, Senate Finance Committee Ranking Member Ron Wyden (D-OR) released a discussion draft of a new regime for the taxation of derivatives. The

Withholding on Air: The IRS Imposes Withholding Tax Rules for Adjustments on Convertible Debt and Equity
  • Mayer Brown LLP
  • USA
  • April 19 2016

“Some people say not to worry about the air. Some people have never had experience with air.” It’s hard to believe that it has been some 37 years

This week at the UK regulators - 11 April 2016
  • Clifford Chance LLP
  • China, United Kingdom, USA
  • April 11 2016

This week, the PRA fined a UK subsidiary of an overseas bank for failures related to assessing, maintaining and reporting on the financial resources

UK pensions update: February 2016
  • Clifford Chance LLP
  • European Union, United Kingdom, USA
  • February 18 2016

The abolition of contracting-out is fast approaching and is raising a number of issues along the way. In particular, trustees and employers should be

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
  • 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