News & Analysis as of

Equity Swaps

Section 871(m) Dividend Equivalent Guidance Including New Transition Relief Expected After Mid-November

by Dechert LLP on

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

Investment Management Legal + Regulatory Update - February 2015

by Morrison & Foerster LLP on

In This Issue: - SEC Proposes Rule Requiring Hedging Disclosure - SEC Reports the Result of its Cybersecurity Sweep of Broker-Dealers and Investment Advisers - House Passes Bill to Ease Volcker Rule and Other...more

Foreign Taxpayers Can Benefit Despite Proposed Regulations

by Bilzin Sumberg on

Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more

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