Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast
Navigating the Once-Obscure German Nonresident Withholding Tax
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Cum-Ex Dividend Trade Investigations
On May 22, 2024, the US Department of Treasury and the IRS issued two important notices—one delaying the full implementation of the withholding rules on dividend equivalent payments, and the other on derivative reporting for...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on swaps and other financial instruments that are linked to US equities. These...more
On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more
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