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Capital Markets Tax Quarterly - Volume 2, Issue 2
Q2 2019 started out with a great deal of hope in the world of capital markets taxation.
United States
6 Aug 2019
2
Legal Update: Section 956's "Deemed Dividend" Rules: An Update For Lenders On Proposed Changes
Section 956 of the US Internal Revenue Code ("Section 956") has historically loomed large in the context of finance transactions because it limited the ability of US borrowers to use overseas assets
United States
23 Apr 2019
3
The Public-Private Partnership Infrastructure Exception To The Internal Revenue Code Section 163(J) Interest Deduction Limitation
On November 26, 2018, the US IRS released an advance version of Revenue Procedure 2018-59, which would allow taxpayers providing certain infrastructure-related services in public-private partnerships to avoid...
United States
28 Jan 2019
4
High-Level Overview Of The Proposed Regulations On Interest Deduction Limitation Rules
On November 26, 2018, the Department of Treasury and US Internal Revenue Service released proposed regulations that flesh out the new Section 163(j) interest limitation rule
United States
4 Dec 2018
5
Proposed Regulations Change Calculus Of Section 956's "Deemed Dividend" For US Corporate Shareholders
On October 31, 2018, the US Internal Revenue Service ("IRS") released proposed regulations ("Proposed Regulations") that, if finalized, may substantially impact the way in which multinational corporations finance their operations.
United States
8 Nov 2018
6
IRS Rules Freddie Mac MBS Restructuring Does Not Trigger Gain Or Loss
Freddie Mac and Fannie Mae will cease issuing PCs and MBSs next year and switch to issuing Uniform Mortgage-Backed Securities ("UMBS") next year
United States
6 Sep 2018
7
Treasury And The IRS Introduce Significant Changes In The Final Section 385 Regulations On Intercompany Debt
This legal update provides a brief summary of the most significant changes included in the Final Regulations.
United States
17 Oct 2016
8
Treasury's New Anti-Inversion Regulations: Do They Go Too Far?
On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping.
United States
11 Apr 2016
9
US Court of Appeals Effectively Kills "Cascading" Theory of Federal Excise Tax in Foreign-To-Foreign Retrocessions
The US Court of Appeals has upheld a lower court decision granting reinsurance company Validus Re a refund of federal excise tax (FET) the company had paid on retrocessions of US-source risks to non-US retrocessionnaires.
United States
28 May 2015
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