News & Analysis as of

Derivatives Foreign Account Tax Compliance Act

Gerald Nowotny - Law Office of Gerald R....

Papa’s Got a Brand New Bag – Innovative Planning Within Private Placement Life Insurance

It has been a while since I have written anything. Oh, the indignity of having to make a living! Most of you know by now that I am a quirky guy with quirky interests and quirky points of view. In that realm, I must say that I...more

Dechert LLP

Final IRS Regulations on Transition from LIBOR to Other Reference Rates

Dechert LLP on

The U.S. Department of the Treasury and the Internal Revenue Service on December 30, 2021, issued final regulations (“Final Regulations”) allowing a tax-free treatment of “covered modifications,” as defined, of certain...more

Cadwalader, Wickersham & Taft LLP

IRS Publishes Final IBOR Transition Regulations

On December 30, 2021, the Treasury Department and IRS issued final regulations to address the taxability of modifications that replace LIBOR or another interbank offered rate (an IBOR) with a qualified rate like SOFR....more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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Investment Advisers - ANNUAL COMPLIANCE REVIEWS - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and procedures...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

Blake, Cassels & Graydon LLP

2016 Federal Budget – Selected Tax Measures

On March 22, 2016, the Minister of Finance tabled Canada’s 2016 Federal Budget (the 2016 Budget). This was the first budget presented by the newly-elected Liberal government, which won a strong majority in the fall 2015...more

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2015: And a Partridge in a Pear Tree: Top 12 Regulatory Heads-up for the...

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1st Day of Christmas – UCITS V* - The UCITS V Directive (UCITS V) introduces specific provisions on: - (i) eligibility, liability and delegation of depositaries; - (ii) remuneration policies; and ...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest - Volume X, Issue 11

In This Issue: - Delaware Proposal Banning Fee-Shifting and Permitting Exclusive Forum Provisions - SEC Charges Insiders for Failure to Update Schedule 13D Disclosures - CBOE Proposes Amendments to...more

Blake, Cassels & Graydon LLP

Year in Review: Legislation and Guidance for Financial Institutions in 2014

2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review....more

Bilzin Sumberg

Editorial: Qualifying for Treaty Benefits Under the “Derivative Benefits” Article

Bilzin Sumberg on

Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...more

Morrison & Foerster LLP

Tax Talk -- Volume 6, No. 1 -- April 2013

In This Issue: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives and Modify Certain Other Tax Rules; After Months of Anticipation, Final FATCA Regulations Released; Congress Considers...more

Eversheds Sutherland (US) LLP

Legal Alert: 2013 Outlook for Insurance Regulation

We end the first month of the year with a report on major insurance topics that we will be watching in 2013. Many of these developments can be traced to discrete events or market or political forces. This year, those...more

Morrison & Foerster LLP

After Months of Anticipation, Final FATCA Regulations Released

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act (“FATCA”). ...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - January 28, 2013

In This Issue: *Financial Industry Developments - CFPB Rule on Originator Compensation - Treasury and IRS FATCA Regulations - Rating Agency Developments *Recent Orrick Alerts - Derivatives Reform in...more

Dechert LLP

Financial Services – Update on UK and European Regulatory Developments

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This update summarises current regulatory developments impacting the asset management sector in the UK and throughout the European Union. In this issue: - Part A – Regulation of Financial Markets - Part B –...more

Eversheds Sutherland (US) LLP

A New FATCA Derivative: ISDA Publishes Protocol Designed To Address the Implications of FATCA on Derivatives Transactions

On August 15, the International Swaps and Derivatives Association, Inc. (ISDA) published the 2012 ISDA FATCA Protocol (the FATCA Protocol). The FATCA Protocol is intended to address the implications of the Foreign Account Tax...more

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