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Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
IRS Issues Proposed Regulations Implementing Base Erosion Anti-Abuse Tax (BEAT) Rules
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
28 Jan 2019
BEATen Up (Again): The IRS Issues Proposed Regulations Under The Base Erosion Anti-Abuse Tax
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
25 Jan 2019
New Case Applies Kovel Privilege To Client–Accountant Emails
The resolution of any complex tax litigation necessarily involves working with accountants as well as with lawyers.
United States
19 Nov 2018
Window Of Opportunity: The IRS Issues Initial Guidance On Qualified Opportunity Zone Rules
It is extremely rare that a section of the US Internal Revenue Code of 1986, as amended (the "Code") ...
United States
29 Oct 2018
Capital Markets Tax Quarterly
Welcome to Mayer Brown's Capital Markets Tax Quarterly (CMTQ). This is a new publication for Mayer Brown's Tax practice, so let us explain what we're about.
United States
23 Oct 2018
Tax Reform Income Acceleration Provision Inapplicable To Accrued Market Discount
On September 27, 2018, the US Internal Revenue Service (the "IRS") released Notice 2018-80 (the "Notice")
United States
4 Oct 2018
GILTI Pleasures: The IRS Releases Proposed Regulations On Global Intangible Low-Taxed Income
Every one of us has some guilty pleasure, whether it's watching soap operas, binging on jelly donuts, attending electronic dance music parties ...
United States
26 Sep 2018
IRS Further Extends Phase-In Of Section 871(m) Regulations By 'Another' 2 Years
On September 20, 2018, the US Internal Revenue Service ("IRS") released Notice 2018-72 (the "Notice") ...
United States
26 Sep 2018
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
Gain Deferral Using Qualified Opportunity Zone Investment Strategies
This Legal Update provides an overview of the "Qualified Opportunity Zone" rules.
United States
10 Aug 2018
Carried Interest Update: US Tax Court Denies Service Provider Partner Status In Informal Partnership
It's not always apparent when a person cast as a partner should be treated as a disguised service provider or employee.
United States
24 Jul 2018
IRS Confirms Loan Commitment Fees Are Deductible Business Expenses
The deduction for interest has been under some pressure lately. In particular, the Tax Cuts and Jobs Act (P.L. 115-97) recently amended Section 163(j) of the Internal Revenue Code of 1986 ...
United States
12 Jul 2018
Biotech Start-up Funding: An Ounce Of Prevention Is Worth A Pound Of Cure
Subject to certain limitations, investors can choose between providing debt and equity funding to a start-up company
United States
12 Oct 2017
Redemption Of Interest In US Partnership Not Taxable To Foreign Investor; Tax Court Refuses To Follow Revenue Ruling 91-32
In general, a non-US person is not subject to US federal income tax when he sells stock of a US corporation.
United States
31 Jul 2017
Withholding On Air: The IRS Imposes Withholding Tax Rules For Adjustments On Convertible Debt And Equity
"Some people say not to worry about the air. Some people have never had experience with air."
United States
21 Apr 2016
FATCA Certifications Delayed And Other Welcomed Guidance Issued
On January 19, 2016, the US Internal Revenue Service issued Notice 2016-08, which announced the intention to amend the Treasury regulations promulgated under chapter 4 of the Internal Revenue Code.
United States
22 Jan 2016
Sharpened Knives: US Internal Revenue Service Continues Slicing Through Barrier Options With CCA 201547004
The efforts of the US Internal Revenue Service (the "IRS") to broadly challenge the purported federal income tax consequences of barrier and basket options has been gathering steam over the past few years.
United States
25 Nov 2015
FATCA Transitional Rules Extended
To ease compliance burdens, the Notice provides that the IRS intends to make the pro rata rule for collateral that secures both grandfathered and non-grandfathered obligations optional.
United States
28 Sep 2015
IRS Releases Final & Temporary HIRE Act Regulations Addressing Section 871(m) Dividend Equivalents
The US Internal Revenue Service has just released final and temporary regulations addressing when payments on swap transactions and equity-linked instruments will be treated as dividend equivalents.
United States
23 Sep 2015
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