Searching Content indexed under Finance and Banking by Mark Leeds ordered by Published Date Descending.
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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
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
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
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
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
Like A Hot Knife Through Butter: The US Congress And Internal Revenue Service Pierce Straight Through Barrier Options
The author and his reviewer each find themselves raising teenage girls, coincidentally attending the same school.
United States
9 Oct 2014
The New Deal: Hedge Fund Management Fees Are Subject To Social Security Taxes
It’s probably fair to speculate that there were significant numbers of tax aficionados among the audience for Ken Burns’ recent public television extravaganza on the Roosevelt dynasty.
United States
24 Sep 2014
United States
4 Mar 2014
Fractional Taxation: IRS Releases Technical Advice Addressing The 10% Securities Rule Applicable To Foreign Bank Branches
Detailed special rules apply to determine whether, and the extent to which, income from a security is considered attributable to the conduct of a banking, financing, or similar business in the United States by a non-US bank.
United States
1 Jul 2013
The IRS Issues Final FATCA Regulations
On January 17, 2013, the Internal Revenue Service (IRS) released 544 pages of final regulations implementing the provisions of the Foreign Account Tax Compliance Act.
United States
28 Jan 2013
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