Peter Connors

Peter Connors

Orrick, Herrington & Sutcliffe LLP

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IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

2/2/2017 - Consumer Financial Products Derivatives Dividend-Equivalent Transactions Exchange-Traded Products Financial Markets Financial Sector Internal Revenue Code (IRC) IRS Master Limited Partnerships Partnerships Qualified Derivatives Dealers (QDDs) Section 871(m) Securities SIFMA Stocks

IRS Releases Transition Guidance for the Dividend Equivalent Rules

On December 2, 2016, the Internal Revenue Service (the “IRS”) issued Notice 2016-76 (the “Notice”), which provides highly anticipated guidance regarding “dividend equivalent” payments under section 871(m) of the Internal...more

12/13/2016 - Dividend-Equivalent Transactions Dividends IRS Qualified Derivatives Dealers (QDDs) Section 871(m) Withholding Tax

IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

11/10/2016 - Bifurcation Debt Debt Instruments Expanded Group Instruments (EGIs) Financial Institutions Financial Sector Foreign Issuers IRS Multinationals Section 385 Stocks U.S. Treasury

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

10/11/2016 - Business Taxes Capital Gains Debt IRS MLPs Partnerships Sale of Assets Tax Liability Tax Rates U.S. Treasury

Derivatives in Review - July 2016

An Overview of Proposed Regulation AT - Orrick attorneys authored an overview of Regulation Automated Trading (known as "Regulation AT") proposed by the Commodity Futures Trading Commission ("CFTC") in the May/June 2016...more

8/2/2016 - Bitcoin Blockchain CFTC Derivatives Digital Currency Distributed Ledger Electronic Trading Financial Markets Financial Sector Innovative Technology IRS Regulation AT Reporting Requirements SEC Security-Based Swaps Swap Dealers Swaps

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

5/18/2016 - Asset Stripping Corporate Taxes Debt Expanded Group Instruments (EGIs) Financial Instruments Internal Revenue Code (IRC) IRS Multinationals Proposed Regulation

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

4/29/2016 - Asset Stripping Earnings Management Foreign Entities Internal Revenue Code (IRC) IRS Multinationals Non-Marketable Debt Instruments Proposed Regulation Tax Planning Taxable Income

IRS Announces Intent to Tax Transfers to Partnerships With Foreign Partners

On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more

11/24/2015 - Corporate Taxes Foreign Affiliates IRS Partnerships Transfer of Assets

Orrick's Derivatives in Review - June 2015

NYDFS Finalizes BitLicense Regulations - On June 3, 2015, the New York Department of Financial Services released its final BitLicense regulations, which it described as "the first comprehensive framework for regulating...more

6/16/2015 - BitLicense CFTC Department of Financial Services Derivatives End-Users IRS Mandatory Clearing Requirements Payment Schedules SEC Securitization Security-Based Swaps SPVs Trade Options

IRS Scripts a New Tune with Final Whistleblowing Regulations

Section 7623 of the Internal Revenue Code (the “Code”), added in 1954, authorizes the Treasury Secretary to pay an award as he deems necessary for “(1) detecting underpayments of tax, or (2) detecting and bringing to trial...more

9/4/2014 - Anti-Retaliation Provisions Internal Revenue Code (IRC) IRS U.S. Treasury Whistleblower Awards Whistleblowers

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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