Sullivan & Cromwell LLP

UK Controlled Foreign Company Reform: Further Draft Legislation on Permanent Changes to the CFC Rules
Emma Hardwick,Michael T. McGowan,Andrew Thomson, February 8, 2012
The UK government has published revised draft legislation for a reformed controlled foreign company (“CFC”) code.

UK Patent Box: UK Government Publishes Draft Legislation Creating a Preferential Tax Regime for Certain Types of Intellectual Property
Emma Hardwick,Michael T. McGowan,Andrew Thomson, January 26, 2012
The UK Government has published draft legislation for a “patent box”.

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...

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