News & Analysis as of

Dividends Anti-Abuse Rule

McDermott Will & Emery

CJEU Rules on Parent-Subsidiary & Interest and Royalties Directives Anti-abuse Clauses

On February 26, 2019 the Court of Justice of the European Union (CJEU) issued the long-awaited judgments on the cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...more

Proskauer - Tax Talks

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)

Proskauer - Tax Talks on

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more

Goodwin

New France-Luxembourg Double Taxation Treaty

Goodwin on

A new double taxation treaty between France and Luxembourg was signed on 20 March 2018 (the “New Treaty”). This New Treaty will replace the current tax treaty dated 1 April 1958, as amended several times and for the last time...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

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

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