Shlomo M. Boehm

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...

Proposed Treasury Regulations Regarding Swaps and Other Notional Principal Contracts
Shlomo M. Boehm,Mark P. Howe,David S. Miller,Daniel J. Mulcahy, September 23, 2011
On Thursday, September 15, the Treasury Department and the Internal Revenue Service issued proposed regulations that affect swaps and other notional principal contracts. The proposed regulations are proposed to be effective for contracts entered into on or after the date the final regulations are...