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Results:1-10 of 170

FATCA tweaks kick "Passthru" withholding back to the future
  • Hogan Lovells
  • USA
  • January 10 2019

Those of us who regularly review debt facilities have probably noticed that the prospective (earliest) application date for FATCA withholding on


New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and guarantees by CFCs
  • Hogan Lovells
  • USA
  • November 14 2018

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations


US Congress members ask SEC for clarity on crypto approach
  • Hogan Lovells
  • USA
  • October 1 2018

What has happened? A group of US Congress members has called on the Securities and Exchange Commission (SEC) to clarify its position in respect of the


US IRS urged to issue "more robust" guidance on virtual currencies
  • Hogan Lovells
  • USA
  • September 25 2018

What has happened? A group of US Congressmen has called on the Internal Revenue Service (IRS) to issue updated guidance on the tax obligations when


IRS issues initial guidance on application of Code Section 162(m) as amended by the Tax Cuts and Jobs Act
  • Hogan Lovells
  • USA
  • August 30 2018

On August 21, the Internal Revenue Service (IRS) issued Notice 2018-68 containing much-awaited interpretive guidance on Section 162(m) of the Internal


US SEC warns about cryptocurrency-based self-directed IRAs
  • Hogan Lovells
  • USA
  • August 20 2018

The US Securities and Exchange Commission (SEC) has advised investors to avoid self-directed individual retirement accounts (IRAs) based on


Doing business in the United States
  • Hogan Lovells
  • USA
  • April 27 2018

The U.S. is one of the easiest jurisdictions in the world in which to do business. Regulatory barriers are generally low, establishing a branch or


US IRS reminds taxpayers to treat cryptocurrencies like "any other property"
  • Hogan Lovells
  • USA
  • March 26 2018

The Internal Revenue Service has reminded US taxpayers to include income from virtual currencies on their annual tax returns


US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available
  • Hogan Lovells
  • USA
  • June 9 2017

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding


IRS issues final regulations on definition of "issue price" for purposes of arbitrage provisions applicable to tax-exempt bonds
  • Hogan Lovells
  • USA
  • December 16 2016

On December 8, 2016, the Internal Revenue Service (IRS) released final regulations (the Final Regulation) on the definition of "issue price" for