Amanda H. Nussbaum

IRS and Treasury Department Publish Anticipated Guidance on "Dividend Equivalent" Payments Derived from Equity Swap Arrangements
Amy G. Drais,Michael D. Fernhoff,Martin T. Hamilton,Arnold P. May,Amanda H. Nussbaum,Stuart L. Rosow, January 30, 2012
On January 19, 2012, the U.S Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued rules governing when equity swaps and similar transactions would result in imposition of U.S. withholding tax under Section 871(m) and related Sections of the Internal...

Treasury Issues Proposed Regulations under Section 382 That Would Ease Compliance Requirements for Tracking Small Shareholder Ownership
Richard M. Corn,Kathleen E. Gerber,Abraham Gutwein,Amanda H. Nussbaum,Stuart L. Rosow, December 6, 2011
On November 23, 2011, the Internal Revenue Service (the "IRS") issued new Proposed Regulations under Section 382 that, if adopted and finalized, would limit the application of the Section 382 segregation rules (discussed in detail below) to public groups in certain circumstances that the...

Temporary Relief from Certain HIRE Act Reporting Requirements
Michael D. Fernhoff,Martin T. Hamilton,Arnold P. May,Amanda H. Nussbaum,Stuart L. Rosow,Raj Tanden, July 1, 2011
On June 21, 2010, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2011-55 (the “Notice”), providing temporary relief from certain information reporting requirements imposed under the Hiring Incentives to Restore Employment Act (the “HIRE Act”). The...