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January 09, 2015

The IRS plans to issue new proposed regulations in 2015 to deal with the tax treatment of swaps with contingent nonperiodic payment swaps. The IRS and Treasury are also expected to issue "in the very near term" final regulations under Section 871(m) of the Internal Revenue Code which requires taxes to be withheld on payments (or deemed payments) to non-U.S. persons of dividend equivalents on certain equity swaps and equity derivatives referencing U.S. stocks. The final regulations were originally targeted for issuance by the end of 2014 with an effective date of January 1, 2016, to allow