News & Analysis as of September 19, 2024

Income Taxes › Derivatives

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Knowing Me, Knowing You! Using Private Derivatives in Personal Tax Planning

Gerald Nowotny - Law Office of Gerald R.... on 8/7/2024

I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more

Tax Guidance on the Transition From Interbank Offered Rates Under OIRA Review

A&O Shearman on 9/3/2019

On August 28, 2019, the U.S. Department of Treasury submitted proposed regulations on the tax consequences related to the phased elimination of interbank offered rates (the “Proposed Regulations”) to the Office of Management...more

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

Akin Gump Strauss Hauer & Feld LLP on 10/8/2018

• 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

Your Daily Dose of Financial News

Robins Kaplan LLP on 8/30/2018

A mix of corporate tax cuts and a strong economy helped propel US corporate profits to a 16.1% year-over-year gain, the best figure in 6 years...more

Law And Accounting Committee Summary Of Current FASB Developments

Butler Snow LLP on 5/19/2016

In March, 2016, the FASB issued Accounting Standards Update No. 2016-09, Compensation - Stock Compensation (Topic 718), Improvements to Employee Share-Based Payment Account. This update simplifies accounting for share-based...more

Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime

Proskauer - Tax Talks on 2/8/2016

Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more

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

Bilzin Sumberg on 9/8/2014

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

Moving from the Academic to the Legislative: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives...

Morrison & Foerster LLP on 2/20/2013

BACKGROUND - For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial derivatives with a “mark-to-market” regime. In the first...more

After Months of Anticipation, Final FATCA Regulations Released

Morrison & Foerster LLP on 1/30/2013

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

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

Eversheds Sutherland (US) LLP on 1/30/2013

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 Draft: ...more

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Income Taxes › Derivatives

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