• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more
5/24/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Debt Financing ,
Intangible Property ,
Investment Funds ,
Opportunity Zones ,
Original Use ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Safe Harbors ,
Tangible Property
• The broader application of Section 871(m) has been delayed further until January 1, 2021 and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S. withholding...more
9/24/2018
/ Anti-Abuse Rule ,
Broker-Dealer ,
Delays ,
Derivatives ,
Dividend-Equivalent Transactions ,
Equity Investors ,
Exchange-Traded Products ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Swaps ,
Tax Evasion ,
Withholding Tax
In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more
8/18/2017
/ Anti-Abuse Rule ,
Broker-Dealer ,
Delays ,
Derivatives ,
Dividend-Equivalent Transactions ,
Equity Investors ,
Exchange-Traded Products ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Section 871(m) ,
Swaps ,
Tax Evasion ,
Withholding Tax