Sullivan & Cromwell LLP

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IRS Seeks Comments on Bilateral Transfer Pricing Safe Harbor: IRS Seeks Public Comments Regarding the Development of a Model Memorandum of Understanding Between U.S. Tax Treaty Partners Outlining Transfer Pricing Safe Harbors for Routine Distribution Services
James R. Gadwood,Donald L. Korb,Alan D. Kravitz,Andrew P. Solomon,S. Eric Wang, March 21, 2013
On March 15, 2013, the Internal Revenue Service announced that it is seeking comments from the public regarding the development of a model memorandum of understanding between Competent Authorities relating to transfer pricing safe harbors for routine distribution functions. The IRS’s...

FATCA: Revised Deadlines: IRS and Treasury Department Issue Notice Postponing Certain FATCA Deadlines and Expanding Scope of FATCA “Grandfather” Rules
Donald L. Korb,Michael Orchowski,Andrew P. Solomon,S. Eric Wang, October 26, 2012
Yesterday, the IRS and Treasury Department issued Announcement 2012-42 (the “Announcement”), which delays certain FATCA compliance deadlines and identifies three new classes of “grandfathered obligations.” Key changes noted in the Announcement include the following:

CFTC Guidance on Extraterritoriality: CFTC Releases Proposed Guidance on and Exemptive Relief from Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act
David J. Gilberg,Eric J. Kadel,Kenneth M. Raisler,Dennis C. Sullivan,Andrea R. Tokheim, July 14, 2012
On June 29, 2012, the Commodity Futures Trading Commission (“CFTC”) issued proposed guidance (“Proposed Guidance”) on the cross-border application of certain swaps provisions under the Commodity Exchange Act (“CEA”) and a proposed exemptive order (“Proposed...

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