David Miller

David Miller

Cadwalader, Wickersham & Taft LLP

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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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