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Searching Content indexed under Tax Authorities by Mark Leeds ordered by Published Date Descending.
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BEATen Up (Again): The IRS Issues Proposed Regulations Under The Base Erosion Anti-Abuse Tax
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
25 Jan 2019
2
IRS Further Extends Phase-In Of Section 871(m) Regulations By 'Another' 2 Years
On September 20, 2018, the US Internal Revenue Service ("IRS") released Notice 2018-72 (the "Notice") ...
United States
26 Sep 2018
3
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
4
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
5
Withholding On Air: The IRS Imposes Withholding Tax Rules For Adjustments On Convertible Debt And Equity
"Some people say not to worry about the air. Some people have never had experience with air."
United States
21 Apr 2016
6
FATCA Certifications Delayed And Other Welcomed Guidance Issued
On January 19, 2016, the US Internal Revenue Service issued Notice 2016-08, which announced the intention to amend the Treasury regulations promulgated under chapter 4 of the Internal Revenue Code.
United States
22 Jan 2016
7
FATCA Transitional Rules Extended
To ease compliance burdens, the Notice provides that the IRS intends to make the pro rata rule for collateral that secures both grandfathered and non-grandfathered obligations optional.
United States
28 Sep 2015
8
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
9
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
10
Like A Hot Knife Through Butter: The US Congress And Internal Revenue Service Pierce Straight Through Barrier Options
The author and his reviewer each find themselves raising teenage girls, coincidentally attending the same school.
United States
9 Oct 2014
11
Important Foreign Account Tax Compliance Act (FATCA) Development For Withholding Agents And Foreign Financial Institutions
Domestic payers of certain types of US-source income and foreign financial institutions (FFIs) must determine whether their payees and account holders are compliant with the Foreign Account Tax Compliance Act (FATCA) and ..
United States
4 Apr 2014
12
United States
 
4 Mar 2014
13
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
14
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
15
The 7% Solution: Structured Dividend Received Deduction Transactions Face Internal Revenue Service Audit Scrutiny
It appears that a 7% effective tax rate can have addictive properties to corporate taxpayers.
United States
6 Jun 2013
16
The IRS Issues Final FATCA Regulations
On January 17, 2013, the Internal Revenue Service (IRS) released 544 pages of final regulations implementing the provisions of the Foreign Account Tax Compliance Act.
United States
28 Jan 2013
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