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IRS Releases Final and New Proposed Regulations That Define “Dividend Equivalent” for U.S. Withholding Tax Purposes

On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more

Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives

I. Introduction - On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed...more

Cyprus: The Day After - The sun will still shine bright

Introduction - Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more

2013 Amendments to United States and Japan Income Tax Treaty

On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more

American Taxpayer Relief Act of 2012 Approved by Congress and Signed by the President

Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more

Legal Alert: The Cliff-Hanger (Chapter One) is Over: Highlights of the American Taxpayer Relief Act of 2012

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more

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