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Searching Content indexed under Tax Authorities by Peter Connors ordered by Published Date Descending.
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Carbon Capture Sequestration – Orrick Responds To The IRS Request For Comments
On May 2, 2019, the Internal Revenue Service ( the "IRS") released Notice 2019-32 (the "Notice") which requested comments for Carbon Oxide Sequestration Section 45Q of the Internal Revenue Code
United States
20 Aug 2019
2
Ninth Circuit Withdraws Controversial Altera Opinion And Will Allow New Judge To Make Ultimate Determination
On August 7, 2018, the Ninth Circuit withdrew its July 24 decision in Altera so that new panel member, Judge Susan P. Graber, can now consider the case.
United States
16 Aug 2018
3
The Final §385 Regulations (Part II) - Classifying Interests In A Corporation
On October 13, 2016, the Treasury Department issued much anticipated regulations under Internal Revenue Code §385. These regulations, which consist of both temporary and final regulations...
United States
27 Feb 2017
4
IRS Releases New Regulations Regarding Dividend Equivalents
On January 19, 2017, the Internal Revenue Service (the "IRS") issued final, temporary, and proposed regulations (the "Regulations") under section 871(m) of the Internal Revenue Code of 1986...
United States
14 Feb 2017
5
Tax Benefit From Leveraged Partnerships Shut Down By New IRS Regulations
The IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged partnerships.
United States
17 Oct 2016
6
IRS Proposes To Revise The Treatment Of Nonperiodic Payments
While the Regulations are designed to resolve issues, many unanswered questions remain.
United States
17 Jun 2015
7
IRS Issues Final Regulations And New Proposed Regulations Regarding Withholding On Derivatives On U.S. Stocks
On December 5, 2013, the Internal Revenue Service issued final regulations and proposed regulations under section 871(m), which address withholding on certain equity-linked notional principal contracts and other financial instruments.
United States
6 Jan 2014
8
IRS Issues Temporary Regulations On The Application Of The Straddle Rules To Debt Instruments
On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations").
United States
4 Nov 2013
9
IRS Issues Changes To The Mixed Straddle Regulations
On August 2, 2013, the IRS issued temporary regulations (the "Temporary Regulations") relating to accrued gain or loss associated with a position that becomes part of a section 1092(b)(2) identified mixed straddle.
United States
10 Sep 2013
10
Recent U.S. Developments in the Financial Products Area*
Perhaps the most innovative financial product of the 1990s was the credit derivative contract. Credit derivative contracts allow parties to transfer and speculate on the creditworthiness of a taxpayer. The contracts usually take the form of a credit derivative swap ("CDS") using an ISDA master agreement.
United States
18 Oct 2005
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