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Results:1-10 of 10

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
  • Proskauer Rose LLP
  • USA, OECD
  • January 25 2019

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid”


The Proposed BEAT Regulations
  • Proskauer Rose LLP
  • USA
  • December 31 2018

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the


Summary of the Opportunity Zone Program
  • Proskauer Rose LLP
  • USA
  • November 8 2018

The Tax Cuts and JOBS Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program. The program is


IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)
  • Proskauer Rose LLP
  • USA
  • October 18 2017

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue


Tax Court Rules that Extensions of Variable Prepaid Forward Contracts Do Not Result in Taxable Exchanges
  • Proskauer Rose LLP
  • USA
  • April 27 2017

Last week, in McKelvey v. Commissioner the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not


IRS Updates Ruling Policy on Corporate Business Purpose and Device Requirements under Section 355
  • Proskauer Rose LLP
  • USA
  • August 29 2016

The U.S. Internal Revenue Service (“IRS”) released Revenue Procedure 2016-45 (the “Revenue Procedure”) on August 26, 2016, permitting taxpayers once


IRS and Treasury Department publish anticipated guidance on "dividend equivalent" payments derived from equity swap arrangements
  • Proskauer Rose LLP
  • USA
  • January 27 2012

On January 19, 2012, the U.S Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued rules governing when equity swaps and similar transactions would result in imposition of U.S. withholding tax under Section 871(m) and related Sections of the Internal Revenue Code of 1986, as amended (the "Code").


Significant changes to the foreign tax credit and other international business tax provisions enacted in The Education Jobs and Medicaid Assistance Act of 2010
  • Proskauer Rose LLP
  • USA
  • August 20 2010

On August 10, 2010, The Education Jobs and Medicaid Assistance Act of 2010 (the "Act") was signed into law by President Obama.


Martin T Hamilton
  • Proskauer Rose LLP