David Miller

David Miller

Cadwalader, Wickersham & Taft LLP

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Latest Publications


New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

10/2/2015 - Annuities Anti-Abuse Rule Broker-Dealer Capital Markets CFTC Convertible Debt Derivatives Dividends Equity Securities Fair Market Value Foreign Exchanges Hedge Funds Insurance Industry IRC IRS K-1 Life Insurance New Regulations SEC Stocks Swaps Trading Platforms U.S. Treasury Withholding Requirements Withholding Tax

New Urgency for Corporate Inversion Transactions (Quorum, March 2014)

Corporate inversions have constituted an active and successful part of the M&A market in 2013 and early 2014, as acquirors have typically traded up on the date of announcement. However, there is now a new urgency for U.S....more

3/27/2014 - Corporate Taxes Foreign Corporations Inversion Mergers U.S. Treasury

Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives

I. Introduction - On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed...more

12/13/2013 - Derivatives Dividends Foreign Investment IRS U.S. Treasury Withholding Tax

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