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Income Taxes › Swaps

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... more +
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 -
Akin Gump Strauss Hauer & Feld LLP

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

Akin Gump Strauss Hauer & Feld LLP on

• 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

Proskauer - Tax Talks

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

Proskauer - Tax Talks on

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

Morgan Lewis

IRS Delays Effective Date for New Regulations on Embedded Loans in Swaps

Morgan Lewis on

The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more

Bilzin Sumberg

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Bilzin Sumberg on

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

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