Mark P. Howe

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, Jason Schwartz, Adam Blakemore.

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, Jason Schwartz, Adam Blakemore.

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, Jason Schwartz, Adam Blakemore.

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, Jason Schwartz, Adam Blakemore.

IRS Finalizes Rule on Financial Products Referencing U.S. Source Dividend Payments

USA - December 16 2019 The IRS clarified requirements as to "certain financial products providing for payments that are contingent upon or determined by reference to U.S...