William Pauls at Sutherland Asbill & Brennan LLP

At Last: Final Regulations Issued Under Section 336(e)

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more

5/14/2013 - Corporate Taxes Distribution Rules IRS Proposed Regulation Stocks

Legal Alert: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

The good news is that, under the recently released Foreign Account Tax Compliance Act (FATCA) regulations, most non-U.S. property and casualty (P&C) insurance and reinsurance companies will not be considered foreign financial...more

5/6/2013 - FATCA Foreign Financial Institutions Non-Financial Firms Reinsurance Reporting Requirements

Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S....

The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more

4/25/2013 - Foreign Corporations International Tax Competitiveness Act of 2013 International Tax Issues Offshore Companies Proposed Legislation Stop Tax Haven Abuse Act

Legal Alert: New Budget Proposals Once Again Target Insurance Companies

On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more

4/16/2013 - Barack Obama Dividends FATCA Federal Budget Financial Crisis Responsibility Fee Life Insurance Private Separate Accounts Reinsurance Reporting Requirements Tax Deductions

Legal Alert: One Shade of GRA: Proposed Regulations Foreshadow the End of the GRA Directive and Provide That "Available Upon...

On January 30, Treasury and the IRS issued proposed regulations relating to the proper filing of gain recognition agreements (GRAs) and other related compliance obligations (the Proposed Regulations). As a general matter, a...more

2/5/2013 - Directors Federal Reserve Gain Recognition Agreements IRS Stocks

Legal Alert: Camping on "The Street": A First Step in the Reform of the Taxation of Financial Instruments and Products

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In brief, the Camp...more

1/30/2013 - Camp Draft Capital Gains Derivatives Hedge Funds Income Taxes

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William Pauls

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