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Results: 1-10 of 19

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



New U.S. tax regulations provide “non-recognition” treatment for nonassigning counterparty on transferred or assigned derivatives
  • Sidley Austin LLP
  • USA
  • July 25 2011

The U.S. Department of Treasury has issued temporary and proposed regulations (the “New Regulations”) addressing whether there is a deemed exchange (resulting in a taxable event) by the nonassigning counterparty (i.e., the remaining party) when the other counterparty assigns or transfers its interest in certain derivative contracts


Tax implications of new ISDA 2010 HIRE Act protocol for equity swap participants
  • Sidley Austin LLP
  • USA
  • September 9 2010

A new ISDA Protocol (the "Protocol"), primarily concerning equity swaps, was released on August 23, 2010


IRS releases audit guidelines on equity swaps
  • Sidley Austin LLP
  • USA
  • February 10 2010

On January 14, 2010, the IRS released an industry directive alerting its field offices that non-U.S. persons may be using abusive total return swaps to avoid U.S. withholding tax on dividends


Connie M. Friesen
  • Sidley Austin LLP

Jon Brose
  • Sidley Austin LLP

Sharp Sorenson
  • Sidley Austin LLP

Nicholas R. Brown
  • Sidley Austin LLP

Michael A. Clark
  • Sidley Austin LLP