News & Analysis as of

Withholding Tax Anti-Abuse Rule

McDermott Will & Emery

Special Report - Collective Investment Schemes & EU Holding Companies: A Multijurisdictional Analysis in Light of the CJEU Danish...

McDermott Will & Emery on

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

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

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities – Additional Delay of Full Implementation until 2021 (Notice 2018-72)

• 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

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities—Further Delay of Full Implementation Until 2019 (Notice 2017-42)

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

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

5 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide