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Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
Treasury Adds Color To Grecian Repeal – Proposed Regulations Implement New Section 864(C)(8) For Sale Of Partnership Interests By Foreign Partners
On December 20, 2018, the US Department of Treasury and the IRS released proposed regulations under Section 864(c)(8) of the Code on the treatment of a foreign partner's transfer of an interest in a partnership...
United States
14 Jan 2019
Capital Markets Tax Quarterly
Welcome to Mayer Brown's Capital Markets Tax Quarterly (CMTQ). This is a new publication for Mayer Brown's Tax practice, so let us explain what we're about.
United States
23 Oct 2018
Tax Reform Income Acceleration Provision Inapplicable To Accrued Market Discount
On September 27, 2018, the US Internal Revenue Service (the "IRS") released Notice 2018-80 (the "Notice")
United States
4 Oct 2018
IRS Rules Freddie Mac MBS Restructuring Does Not Trigger Gain Or Loss
Freddie Mac and Fannie Mae will cease issuing PCs and MBSs next year and switch to issuing Uniform Mortgage-Backed Securities ("UMBS") next year
United States
6 Sep 2018
Redemption Of Interest In US Partnership Not Taxable To Foreign Investor; Tax Court Refuses To Follow Revenue Ruling 91-32
In general, a non-US person is not subject to US federal income tax when he sells stock of a US corporation.
United States
31 Jul 2017
Treasury's New Anti-Inversion Regulations: Do They Go Too Far?
On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping.
United States
11 Apr 2016
Protecting Americans From Tax Hikes Act Of 2015: Effects On Taxation Of Investment In US Real Estate
On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015.
United States
23 Dec 2015
A Matter Of Semantics: Validus Reinsurance Invalidates Foreign-To-Foreign Withholding
President Bill Clinton famously attempted to come to terms with the meaning of the verb "is" when he was caught engaging in hanky-panky at the White House: "It depends on what the meaning of the word 'is' is.
United States
30 Jun 2015
Proposed US Treasury Regulations Attempt to Distinguish "Active" Insurance Companies from Hedge Funds
Offshore insurance companies can provide substantial tax benefits to their owner-insureds through current deductions for the insurance premium and, if properly structured, deferral on reserve investments.
United States
28 Apr 2015
Recent Developments Concerning US Tax Code Section 871(m) Dividend Equivalent Withholding Rules
Two developments may be converging in a way that will result in delayed effective dates for US final dividend equivalent regulations.
United States
3 Feb 2015
The IRS And Treasury Issue New Anti-Inversion Guidance
Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service ("IRS") and the Treasury Department ("Treasury") released Notice 2014-52 ("Notice") on September 22, 2014, describing new regulations to be issued by the government to curtail inversion transactions.
United States
26 Sep 2014
Do What I Say, Not What I Do: The US Internal Revenue Service Finalizes Changes To The Mixed Straddle Rules
A common parenting conundrum is presented by the larger sibling who continually uses force to get his or her way with their smaller counterpart.
United States
22 Jul 2014
IRS And Treasury Issue Long-Awaited Guidance On Corporate Inversions And "Disqualified Stock"
On January 16, 2014, the Internal Revenue Service (the "IRS") and the Treasury Department (the "Treasury") issued longawaited temporary and proposed regulations under Code section 78741 relating to corporate inversions (the "Regulations").
United States
30 Jan 2014
Announcement 2012-42: Timelines For Due Diligence And Other Requirements Under FATCA
FFIs, grandfathered obligation On October 24, 2012, the Internal Revenue Service (IRS) and the US Department of Treasury (Treasury) issued "Announcement 2012-42: Timelines for Due Diligence and Other Requirements under FATCA" (the Announcement).
United States
2 Nov 2012
New Proposed Regulations Treat Credit Default Swaps As Notional Principal Contracts
The US Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued proposed regulations on September 16, 2011 (the "proposed regulations") that, if finalized, will treat credit default swaps (CDSs) and certain other swaps as notional principal contracts (NPCs).
United States
14 Oct 2011
Internal Revenue Service Issues Guidance Extending FATCA’s Effective Date and Details a Timeline for Implementation
On July 14, 2011, the Internal Revenue Service (IRS) announced rules in Notice 2011-53 (the Notice) that modify FATCA’s January 1, 2013 statutory effective date, as a result of the comments submitted to the IRS and Treasury Department (Treasury) relating to the practical challenges of implementing FATCA by the statutory effective date.
United States
22 Jul 2011
Regulations Proposed by US Treasury Department and Internal Revenue Service Require Financial Institutions to Report Interest Paid to Nonresident Aliens
On January 7, 2011, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations that would impose information collection and reporting requirements on US financial institutions with respect to bank deposit interest paid to non-US persons (the "2011 proposed regulations").
United States
17 Jan 2011
US IRS Issues Preliminary FATCA Guidance Establishing Due Diligence Procedures and Information Reporting Rules for Foreign Financial Institutions
On August 27, 2010, the US Internal Revenue Service (the "IRS") published Notice 2010-60 (the "Notice") containing preliminary guidance regarding implementation of the so-called FATCA rules.
United States
21 Sep 2010
Proposed Legislation Permits Foreign Shareholders to Own Increased Percentage of Domestic REITs Without Becoming Subject to FIRPTA
On July 30, 2010, the US House of Representatives passed H.R. 5901, the Real Estate Jobs and Investment Act of 2010, by a vote of 402 to 11.
United States
18 Aug 2010
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