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Proposed Regulations Address Withholding Requirements on Deemed Dividends on Convertible Bonds and Similar Instruments

USA - April 18 2016 The Internal Revenue Service (IRS) has released proposed regulations (the Proposed Regulations) providing guidance to corporate issuers and…

Timothy J. Manion

President’s Budget Proposes to Eliminate Tax Gap

USA - February 15 2016 On February 9, 2016, the White House released President Obama's fiscal 2017 budget, which proposes to eliminate the statutory gap that currently…

Bridget R. O’Neill, Joseph M. Paral

Congress targets partnerships: new partnership tax audit rules

USA - November 2 2015 On November 2, 2015, the Bipartisan Budget Act of 2015, (the Budget Act) was enacted, which contains new rules for partnership tax audits. The Budget…

Christian Brause, Timothy J. Devetski, Bridget R. O’Neill

IRS issues final regulations on dividend equivalents under Section 871(m)

USA - September 18 2015 On September 17, 2015, the Treasury Department and the Internal Revenue Service (IRS) released final, temporary and proposed regulations (the Final…

Timothy J. Manion

Recent IRS guidance on electronic K-1s

USA - March 20 2012 Recent IRS guidance provides detailed requirements for a partnership to furnish K-1s (Partner’s Share of Income, Deductions, Credits, etc.) to partners electronically (e.g., by e-mail or through a website).

Jon Brose, Bridget R. O’Neill