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Searching Content indexed under Finance and Banking by Mark Howe ordered by Published Date Descending.
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Investment Fund Defends Its Tax Treatment Of Basket Options
An investment fund challenged an IRS determination that various contracts entered into between the fund and an investment bank resulted in the fund
United States
7 Oct 2019
2
Taxing Times: The Death Of LIBOR
Regulators have cautioned that LIBOR—which serves as a reference rate for approximately $35 trillion dollars of debt and derivatives—will be phased out as early as the end of 2021.
United States
28 Feb 2019
3
Cadwalader Attorneys Analyze Proposed Regulations Regarding Opportunity Zones
Cadwalader attorneys analyzed proposed regulations, issued on October 19, 2018 by the IRS and U.S. Treasury Department ("Treasury"), relating to the new Opportunity Zone program.
United States
7 Nov 2018
4
Treasury Issues Proposed Regulations On Opportunity Zones
On October 19, 2018, the Internal Revenue Service (the "IRS") and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program.
United States
1 Nov 2018
5
Effects Of House Tax Reform Bill On Securitizations And Funds
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the "Bill").
United States
14 Nov 2017
6
Application Of New Debt-Equity Regulations To Securitizations
Unlike the proposed regulations issued in April, the new regulations do not apply to debt issued by foreign securitizations that are treated as corporations for U.S. tax purposes, such as most foreign CLOs.
United States
2 Nov 2016
7
Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions And Reservations By Government
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. tax purposes.
United States
1 Nov 2016
8
Proposed QI Agreement Addresses Cascading Withholding On Dividend Equivalents
As discussed in a prior Clients & Friends Memo, section 871(m) of the Internal Revenue Code imposes withholding on "dividend equivalents" paid on derivatives that reference U.S. equity securities.
United States
11 Jul 2016
9
Camp’s Market Discount Proposal Is A Mixed Bag For Distressed Debt
Are distressed debt investors required to treat their speculative investment gains as ordinary interest income under the market discount rules, while continuing to treat their investment losses as capital losses?
United States
24 Mar 2015
10
New Proposed And Temporary Regulations Address U.S. Withholding Tax On Cross-Border Equity Derivatives
On Thursday, January 19, the Internal Revenue Service (the "IRS") and the Treasury Department issued proposed and temporary regulations under section 871(m) of the Internal Revenue Code.
United States
30 Jan 2012
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