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A New Approach to VAT Recovery

United Kingdom - January 22 2020 One of the more complicated issues in the world of VAT is the question of the entitlement to VAT recovery of certain holding companies and entities...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Jason Schwartz.

IRS Extends Delta-One Test for Withholding on Dividend Equivalents

USA - January 22 2020 On December 16, the IRS issued Notice 2020-2, which extends the phase-in of withholding under section 871(m). This is the latest in a series of such...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Jason Schwartz.

IRS Issues Final Opportunity Zone Regulations

USA - January 22 2020 I. Introduction On December 19, 2019, the IRS and Treasury issued final regulations on the Opportunity Zone program. The Opportunity Zone program is...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Jason Schwartz.

IRS Adds Transition Relief for Proposed NOL Limitation Rules on Built-in Gains and Losses

USA - January 22 2020 Finally responding to broad criticism, the IRS has updated its section 382 proposed regulations to provide transition relief, delaying the...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Jason Schwartz.

IRS Proposes Narrowing Debt Recast Rules

USA - December 11 2019 Regulations issued in 2016 treat a putative debt instrument as equity if, among other things, (1) the instrument is issued to a person related to the...

Linda Z. Swartz, Gary T. Silverstein, Mark P. Howe, Jason Schwartz.