Searching Content indexed under Withholding Tax by Mayer Brown ordered by Published Date Descending.
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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
Dividend Equivalent Regulations Still In Limbo For Transactions After 2018
In the meantime, practitioners may be left wondering and hoping for the best but planning for the worst.
United States
16 Aug 2018
A Brief Overview Of Mining In Senegal
Senegal is a civil law jurisdiction, meaning that the core principles of law are codified and serve as the primary source of law.
22 Jun 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
Protecting Americans From Tax Hikes Act Of 2015: Effects On Taxation Of Investment In US Real Estate
On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015.
United States
23 Dec 2015
WTO Panel Rejects Argentina's Tax Transparency Penalties
Before a World Trade Organization ("WTO") dispute settlement panel, Panama challenged Argentina's imposition of certain tax measures against services and service suppliers from countries deemed "not cooperating for tax transparency purposes" by the Argentine government under Decree No. 589/2013.
8 Oct 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
A Matter Of Semantics: Validus Reinsurance Invalidates Foreign-To-Foreign Withholding
President Bill Clinton famously attempted to come to terms with the meaning of the verb "is" when he was caught engaging in hanky-panky at the White House: "It depends on what the meaning of the word 'is' is.
United States
30 Jun 2015
Process Is Its Own Reward: The IRS Modifies FATCA Effective Dates & Interim Compliance Standards
On May 2, 2014, there were exactly 60 days until withholding and due diligence rules under the Foreign Account Tax Compliance Act ("FATCA") became effective. Notwithstanding the fact that the US Internal Revenue Service (the "IRS") has promulgated well over 1,000 pages of proposed, temporary and final rules, substantial uncertainty continues to exist over how the rules can be competently administered.
United States
7 May 2014
Important Foreign Account Tax Compliance Act (FATCA) Development For Withholding Agents And Foreign Financial Institutions
Domestic payers of certain types of US-source income and foreign financial institutions (FFIs) must determine whether their payees and account holders are compliant with the Foreign Account Tax Compliance Act (FATCA) and ..
United States
4 Apr 2014
An In-Depth Look At The 2013 IRS Final And Proposed Regulations On Cross-Border Dividend Equivalents Paid On Swaps And In Security Lending Transactions
The waiting for the final regulations addressing when US federal income tax withholding would be imposed on dividend equivalent payments made to non-US persons under notional principal contracts and in security lending transactions bore a strong similarity to the plight of nine-year-old Ralphie in Jean Shepherd’s "A Christmas Story."
United States
17 Feb 2014
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