News & Analysis as of

Tax Reform Section 871(m)

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

Morrison & Foerster LLP

Tax Talk: Volume 10, Issue 3

EDITOR’S NOTE - Tax Reform (or whatever you want to call it) is in full swing as this edition of Tax Talk goes to press. The House has passed H.R. 1 and the Senate Finance Committee has approved its own version of the Tax...more

Morrison & Foerster LLP

MoFo Tax Talk: Volume 10, Issue 1

EDITOR’S NOTE - We held up Tax Talk this quarter in order to bring you the latest on the Trump administration’s tax reform plans. Unfortunately, the one-page plan and transcript of the press conference released on April 26...more

Morrison & Foerster LLP

MoFo Tax Talk: Volume 9, Issue 4

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

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