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Internal Revenue Code (IRC) Delays

Husch Blackwell LLP

Deadline Mounts To Amend Deferred Compensation Plans For Section 162(m) Changes

Husch Blackwell LLP on

Certain deferred compensation plans and agreements maintained by publicly held corporations and subject to Section 409A of the Internal Revenue Code may need to be amended before December 31, 2020, to reflect changes in the...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities – Additional Delay of Full Implementation until 2021 (Notice 2018-72)

• 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

Burr & Forman

2018 Budget Deal Delays Several Affordable Care Act Taxes and Fees

Burr & Forman on

On January 22, 2018, President Trump signed into law H.R. 195 (hereinafter referred to as the “2018 Budget Deal”) which ended the federal government shutdown and funds the federal government through February 8, 2018. In...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities—Further Delay of Full Implementation Until 2019 (Notice 2017-42)

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

BakerHostetler

Employer Shared Responsibility Final Regulations Offer Partial Temporary Enforcement Relief

BakerHostetler on

Enforcement of the employer shared responsibility provisions of the Affordable Care Act (ACA) has been further delayed for employers with between 50 and 99 full-time equivalent employees and temporarily eased for employers...more

King & Spalding

The IRS Delays the Information Reporting Requirements and the Employer Shared Responsibility Penalty

King & Spalding on

On July 9, 2013, Notice 2013-45 (the "Notice") was issued to provide transition relief during 2014 from the requirements of Sections 6055, 6056 and 4980H of the Internal Revenue Code ("Code"). Code Section 6055 requires...more

Eversheds Sutherland (US) LLP

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

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