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.
Senator Ron Wyden (D-OR) introduced a draft bill that would amend the Internal Revenue Code to revise the tax treatment of derivatives and their underlying investments.