Jeffrey D. Hochberg

Foreign-Targeted Bearer Bonds: IRS Issues Transitional Guidance on the Upcoming “Bearer Bond” Repeal
Jeffrey D. Hochberg,Donald L. Korb,Andrew S. Mason,Michael Orchowski,Andrew P. Solomon,S. Eric Wang, March 19, 2012
On March 7, 2012, the IRS issued Notice 2012-20 (the “Notice”), which provides transitional guidance regarding the upcoming sunset of the U.S. tax law provisions that permit the issuance of “foreign-targeted bearer” obligations. The rules set forth in the Notice will...

Final Fee Disclosure Rules for Service Providers to Pension Plans: Department of Labor Regulations Modify Fee Disclosure Rules for Service Providers to Pension Plans
Rebecca S. Coccaro,Jeffrey D. Hochberg,Malcolm S. Hochenberg,Andrew S. Mason,David J. Passey,Marc R. Trevino, February 24, 2012
The Department of Labor recently issued final fee disclosure regulations for service providers to pension plans, 401(k) plans and other similar arrangements (the “Final Regulations”). The Final Regulations in large part adopt the interim final regulations issued by the Department of...

Withholding Tax on Dividend Equivalent Payments: IRS and Treasury Issue Temporary and Proposed Regulations on “Dividend Equivalents” on “Specified Notional Principal Contracts”
Judith R. Fiorini,David P. Hariton,Jeffrey D. Hochberg,Andrew D. Moin,Michael Orchowski,S. Eric Wang, January 26, 2012
Section 871(m) of the Code requires taxpayers to treat certain “dividend equivalent” payments on “specified notional principal contracts” (“specified NPCs”), among other types of transactions, as U.S.- source dividends, thereby subjecting them to the withholding...