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IRS extends relief for Section 871(m) regulations

USA - August 31 2022 Last week, the Internal Revenue Service (IRS) issued Notice 2022-37, which further extends the phase-in period for compliance with final regulations…

Jonathan A. Sambur

Inflation Reduction Act targets carried interests

USA - July 30 2022 On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The…

Daniel R. McKeithen, Wes Sheumaker, H. Karl Zeswitz

Proposed regulations issued under section 1256 with respect to foreign currency options

USA - July 14 2022 Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue…

Robert S. Chase II

Anticipating the end: IRS finalizes LIBOR transition guidance

USA - January 26 2022 Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and…

J. Tyler Moser, Jonathan A. Sambur

Partial Brexit? For income tax treaty purposes, US and UK competent authorities vote to remain

European Union, United Kingdom - August 3 2021 While the United Kingdom left the European Union (EU) last year, the competent authorities of United States and United Kingdom have agreed that the…

Robert S. Chase II