Jonathan Sambur

Eversheds Sutherland (US) LLP

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Latest Posts › Proposed Regulation

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Proposed regulations reduce flexibility of foreign currency mark-to-market election

On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more

9/4/2024 / Foreign Currency , Internal Revenue Code (IRC) , IRS , Proposed Regulation , U.S. Treasury

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

8/9/2024 / Basket Transactions , Disclosure Requirements , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Reform , U.S. Treasury

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

5/17/2024 / Business Entities , Domestic Corporations , Final Rules , Financial Regulatory Reform , Foreign Persons , IRS , Proposed Regulation , Registered Investment Companies (RICs) , Regulatory Agenda , U.S. Treasury

IRS issues proposed regulations for broker reporting of digital assets

On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (88 FR 59576) that detail the information reporting requirements with respect to brokers of...more

9/11/2023 / Brokers , Digital Assets , IRS , Proposed Regulation , Reporting Requirements , Transaction Reporting , U.S. Treasury

Anticipating the end: IRS finalizes LIBOR transition guidance

Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more

1/27/2022 / Alternative Reference Rates Committee (ARRC) , Benchmarks , International Tax Issues , IRS , ISDA , Libor , Proposed Regulation , Revenue Procedures , Secured Overnight Funding Rate (SOFR) , U.S. Treasury

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