BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more
Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more
On July 12, 2013, the IRS issued new guidance regarding FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers. In particular, the IRS (1) revised certain elements of the timeline for FATCA...more