On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more
2/2/2017
/ Consumer Financial Products ,
Derivatives ,
Dividend-Equivalent Transactions ,
Exchange-Traded Products ,
Financial Institutions ,
Financial Markets ,
Internal Revenue Code (IRC) ,
IRS ,
Master Limited Partnerships ,
Partnerships ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Securities ,
SIFMA ,
Stocks
On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more
On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more