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."
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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.
Elizabeth Warren (D-MA), Tammy Baldwin (D-WI), Sherrod Brown (D-OH), Mark Pocan (D-WI) and Pramila Jayapal (D-WA) introduced a bill to govern the private funds that engage in change in control transactions.
The IRS and the U.S. Treasury Department examined proposed regulations to the Internal Revenue Code that would recharacterize certain debt instruments issued to related parties as equity for U.S. federal income tax purposes.
The Internal Revenue Service and the Treasury will hold a public hearing to review jointly proposed debt-equity regulations. The proposed regulations were published in the Federal Register.