On April 4, 2016, the Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) issued (i) final and temporary regulations addressing inversion transactions (t...
The Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) on April 4, 2016 released proposed regulations under Section 385 of the Internal Revenue Code tha...
On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that concludes that an offshore master fund and its offshore feeder f...
Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends for withholding tax purposes. On December 4, 2013, the Treasury D...
Section 871(m) of the Internal Revenue Code, enacted in 2010, imposes withholding tax on, among other things, “dividend equivalents” paid to foreign counterparties pursuant to “spec...
On July 22, the Tax Court published its decision in the case of Anschutz Company v. Commissioner, involving a taxpayer that (indirectly) engaged in various prepaid variable forward contra...
On December 9, the House of Representatives will consider a bill to extend a variety of expiring tax provisions. As had been expected, the bill will include as revenue raisers a revised v...
The Internal Revenue Service (the “IRS”) has released an internal memorandum (the “Memorandum”), from the Office of Chief Counsel to the Director of Field Operations in Manhattan ...
This morning, the Obama Administration provided more detail on its previously announced plan to reform the U.S. tax laws relating to the taxation of income earned by foreign subsidiaries ...
Bills introduced this week in both the House and the Senate contain two provisions that are of particular significance to hedge funds. One provision would materially alter the tax treatme...
