Jason D. Schwartz

Application of Proposed FATCA Regulations to Foreign Investment Vehicles
Shlomo M. Boehm,David S. Miller,Jason D. Schwartz, March 1, 2012
On February 8, the Internal Revenue Service issued proposed regulations that provide guidance on the “FATCA provisions” contained in sections 1471-1474 of the Internal Revenue Code.1 The purpose of FATCA is to reduce U.S. tax evasion by requiring “foreign financial...

New Proposed and Temporary Regulations Address U.S. Withholding Tax on Cross-Border Equity Derivatives
Shlomo M. Boehm,Mark P. Howe,David S. Miller,Daniel J. Mulcahy,Harley Raff,Jason D. Schwartz, January 26, 2012
On Thursday, January 19, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed and temporary regulations under section 871(m) of the Internal Revenue Code. These regulations provide guidance on cross-border swaps and other equity-linked instruments whose...