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U.S. Withholding on Synthetic Trades over U.S. Equities (Section 871(m)) – Additional Delay of Full Implementation until 2023

• The broader application of Section 871(m) has again been delayed, this time until January 1, 2023 and as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S....more

Baucus Post-2016 Proposal: No Change to PTC & ITC Reduced to 20 Percent

Today, the chairman of the Senate Finance Committee, Max Baucus (D-MT), released his proposal for energy tax incentives as part of overall tax reform. The proposal is thoughtful and merits serious consideration by the...more

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