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Tax hedging policies for insurance companies how to avoid an expensive foot fault
  • Greenberg Traurig LLP
  • USA
  • August 19 2015

Insurance companies are in the business of assuming risk for a fee. Fire, casualty, medical expenses, catastrophic weather events, interest rate

Financial services update vol. 10, issue 24
  • Winston & Strawn LLP
  • United Kingdom, USA
  • July 20 2015

In April of this year, the Department of Labor (“DOL”) proposed a rule which amends the definition of “fiduciary” under the Employee Retirement

The IRS identifies certain basket derivatives as reportable transactions
  • Debevoise & Plimpton LLP
  • USA
  • July 17 2015

On July 8, 2015, the IRS issued Notices 2015-47 and 2015-48, which identify as reportable transactions certain derivative contracts that reference a

New guidance regarding basket derivatives
  • Greenberg Traurig LLP
  • USA
  • July 15 2015

On July 8, the Internal Revenue Service (the IRS) issued two new pieces of guidance regarding certain derivatives on baskets of assets. One is old

IRS targets use of basket option contracts and basket contracts by hedge funds and other taxpayers as tax avoidance transactions
  • Sutherland Asbill & Brennan LLP
  • USA
  • July 15 2015

On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use

New disclosure requirement for derivatives over “basket positions” that are controlled by the counterparty
  • Sullivan & Cromwell LLP
  • USA
  • July 9 2015

In Notices issued yesterday (Notices 2015-47 and 2015-48), the IRS implemented disclosure requirements for derivative transactions (including swap

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