Search
Searching Content indexed under Income Tax by Mark Leeds ordered by Published Date Descending.
Links to Result pages
 
1 2  
>>Next
 
Title
Country
Organisation
Author
Date
1
IRS Issues Proposed Regulations Implementing Base Erosion Anti-Abuse Tax (BEAT) Rules
On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules.
United States
28 Jan 2019
2
Window Of Opportunity: The IRS Issues Initial Guidance On Qualified Opportunity Zone Rules
It is extremely rare that a section of the US Internal Revenue Code of 1986, as amended (the "Code") ...
United States
29 Oct 2018
3
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
4
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
5
GILTI Pleasures: The IRS Releases Proposed Regulations On Global Intangible Low-Taxed Income
Every one of us has some guilty pleasure, whether it's watching soap operas, binging on jelly donuts, attending electronic dance music parties ...
United States
26 Sep 2018
6
Carried Interest Update: US Tax Court Denies Service Provider Partner Status In Informal Partnership
It's not always apparent when a person cast as a partner should be treated as a disguised service provider or employee.
United States
24 Jul 2018
7
IRS Confirms Loan Commitment Fees Are Deductible Business Expenses
The deduction for interest has been under some pressure lately. In particular, the Tax Cuts and Jobs Act (P.L. 115-97) recently amended Section 163(j) of the Internal Revenue Code of 1986 ...
United States
12 Jul 2018
8
Biotech Start-up Funding: An Ounce Of Prevention Is Worth A Pound Of Cure
Subject to certain limitations, investors can choose between providing debt and equity funding to a start-up company
United States
12 Oct 2017
9
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
10
Sharpened Knives: US Internal Revenue Service Continues Slicing Through Barrier Options With CCA 201547004
The efforts of the US Internal Revenue Service (the "IRS") to broadly challenge the purported federal income tax consequences of barrier and basket options has been gathering steam over the past few years.
United States
25 Nov 2015
11
IRS Releases Final & Temporary HIRE Act Regulations Addressing Section 871(m) Dividend Equivalents
The US Internal Revenue Service has just released final and temporary regulations addressing when payments on swap transactions and equity-linked instruments will be treated as dividend equivalents.
United States
23 Sep 2015
12
Out-Of-The-Money: The IRS Designates Basket Options As Listed
It's been a long hard road for barrier options.
United States
20 Jul 2015
13
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
14
Mission Creep: The Expanding Role Of The Debt Modification Regulations
The 2014 Burning Man Festival was an incredible experience, in part, because it forced one of your authors completely out of his comfort zone.
United States
12 Feb 2015
15
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
16
The New Deal: Hedge Fund Management Fees Are Subject To Social Security Taxes
It’s probably fair to speculate that there were significant numbers of tax aficionados among the audience for Ken Burns’ recent public television extravaganza on the Roosevelt dynasty.
United States
 
24 Sep 2014
17
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
18
United States
 
4 Mar 2014
19
An In-Depth Look At The 2013 IRS Final And Proposed Regulations On Cross-Border Dividend Equivalents Paid On Swaps And In Security Lending Transactions
The waiting for the final regulations addressing when US federal income tax withholding would be imposed on dividend equivalent payments made to non-US persons under notional principal contracts and in security lending transactions bore a strong similarity to the plight of nine-year-old Ralphie in Jean Shepherd’s "A Christmas Story."
United States
17 Feb 2014
20
Holiday Party: The IRS Releases Final Regulations On Cross-Border Dividend Equivalents Paid On Swaps And In Security Lending Transactions
The waiting for the final regulations addressing when US federal income tax withholding would be imposed on dividend equivalent payments made to non-US persons under notional principal contracts ("NPCs" or "swaps") and in security lending transactions bore a strong similarity to the plight of nine-year-old Ralphie in Jean Shepherd’s "A Christmas Story."
United States
 
12 Dec 2013
Links to Result pages
 
1 2  
>>Next