JONES DAY TALKS®: Derivatives Market Volatility Brings New Concerns and More Regulatory Scrutiny
JONES DAY TALKS®: Carbon Markets are Booming, and Regulators are Watching
JONES DAY TALKS®: Energy Derivatives and Regulatory Enforcement by the CFTC and FERC
JONES DAY TALKS®: CFTC and DOJ Target Derivatives Trading Across Industries
WORD OF THE DAY® for Hedge Funds – Derivative
Cross-Border Regulation of Swaps Update from ISDA's Robert Pickel (Part 1)
A Look at Forensic Accounting and Financial Fraud
Regulation 2013: Dodd-Frank Position Limits, CFTC Reuthorization, Regulatory Harmonization
Enterprise Risk Management is widely used in many industries and businesses. Risk managers use increasingly sophisticated approaches, methods, analytics, and frameworks to manage complex, interrelated, and interconnected...more
Are there differences in the way in which weather derivatives and weather insurance are taxed? Yes. Weather insurance products, including parametric insurance, are taxed as insurance; and derivatives are taxed in accordance...more
The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more
On November 24, 2020, the U.S. Securities and Exchange Commission (SEC) proposed amendments to Rule 701 and Form S-8. In a companion release, the SEC also proposed amendments to Rule 701 and Form S-8 to permit, on a temporary...more
The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more
• The broader application of Section 871(m) has been delayed further until January 1, 2021 and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S. withholding...more
In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more
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
The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more
On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents”...more
On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more
After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more