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IRS Issues Final Regulations and New Proposed Regulations Regarding Withholding on Derivatives on U.S. Stocks

On December 5, 2013, the Internal Revenue Service ("IRS") issued final regulations (the "Final Regulations") and proposed regulations (the "2013 Proposed Regulations") under section 871(m), which address withholding on...more

12/30/2013 - Derivatives IRS Stocks Withholding Requirements

IRS Issues Temporary Regulations on the Application of the Straddle Rules to Debt Instruments

On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more

10/16/2013 - Debt Foreign Currency IRS

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