The IRS delayed implementing certain rules that are intended to prevent non-U.S. persons from using derivative instruments to avoid U.S. withholding tax on U.S. equities.
The IRS finalized requirements related to certain financial products that provide for "payments contingent upon, or determined by, reference to U.S. source dividend payments."
The IRS issued final regulations removing "minimum documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for Federal tax purposes."
Cadwalader attorneys reviewed recently proposed IRS regulations confirming that transitions from LIBOR and other interbank offered rates to alternative reference rates in debt instruments and derivatives will not be taxable events.
The IRS proposal amending certain regulations to address the transition from interbank offered rates to other reference rates for debt instruments and non-debt contracts was published in the Federal Register.
The IRS proposed amending certain tax income regulations to provide guidance on the transition from interbank offered rates to other reference rates for debt instruments and non-debt contracts.
An investment fund challenged an IRS determination that various contracts entered into between the fund and an investment bank resulted in the fund having effective ownership of the positions that were the subject of the contracts.
