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Adobe PDFThe IRS and Treasury Issue New Anti-Inversion Guidance
James R. Barry, Jason S. Bazar, Lee Morlock; Mayer Brown LLP;
Legal Alert/Article
September 26, 2014, previously published on September 25, 2014
Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service (“IRS”) and the Treasury Department (“Treasury”) released Notice 2014-52 (“Notice”) on September 22, 2014, describing new...

 

Adobe PDFDo What I Say, Not What I Do: The US Internal Revenue Service Finalizes Changes to the Mixed Straddle Rules
James R. Barry, George W. Craven, Mark H. Leeds; Mayer Brown LLP;
Legal Alert/Article
July 22, 2014, previously published on July 21, 2014
In 1981, when Congress enacted the straddle rules preventing selective loss recognition, it directed the IRS to allow taxpayers to recognize built-in gain and loss on mixed straddles. In response, the IRS wrote regulations that permit such gain and loss recognition. The IRS has changed its view and...

 

Adobe PDFIRS and Treasury Issue Long-Awaited Guidance on Corporate Inversions and “Disqualified Stock”
James R. Barry, Jason S. Bazar, Michael K. Marion, Lee Morlock; Mayer Brown LLP;
Legal Alert/Article
January 31, 2014, previously published on January 27, 2014
On January 16, 2014, the Internal Revenue Service (the “IRS”) and the Treasury Department (the “Treasury”) issued longawaited temporary and proposed regulations under Code section 7874 relating to corporate inversions (the “Regulations”).

 

Adobe PDFAnnouncement 2012-42: Timelines for Due Diligence and Other Requirements Under FATCA
James R. Barry, Donald C. Morris, Jonathan A. Sambur, Joy Williamson; Mayer Brown LLP;
Legal Alert/Article
November 8, 2012, previously published on November 1, 2012
On October 24, 2012, the Internal Revenue Service (IRS) and the US Department of Treasury (Treasury) issued “Announcement 2012-42: Timelines for Due Diligence and Other Requirements under FATCA” (the Announcement). FATCA generally requires a 30% withholding tax be imposed on (i) foreign...

 

HTMLNew Proposed Regulations Treat Credit Default Swaps as Notional Principal Contracts
James R. Barry, James E. Clegg, Michael K. Marion, Russell E. Nance; Mayer Brown LLP;
Legal Alert/Article
October 14, 2011, previously published on October 13, 2011
The US Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations on September 16, 2011 (the “proposed regulations”) that, if finalized, will treat credit default swaps (CDSs) and certain other swaps...

 

Adobe PDFUS Treasury Department and Internal Revenue Service Issue Supplementary FATCA Guidance
James R. Barry, Megan K. Hall, Donald C. Morris, Jonathan A. Sambur; Mayer Brown LLP;
Legal Alert/Article
May 2, 2011, previously published on April 28, 2011
On April 8, 2011, the Internal Revenue Service (the “IRS”) released Notice 2011-34 (the “Notice”) regarding reporting and withholding requirements pursuant to FATCA (sections 1471 through 1474 of the Internal Revenue Code (the “Code”)). The Notice supplements...

 

HTMLRegulations Proposed by US Treasury Department and Internal Revenue Service Require Financial Institutions to Report Interest Paid to Nonresident Aliens
James R. Barry, Megan K. Hall, Donald C. Morris, Jonathan A. Sambur; Mayer Brown LLP;
Legal Alert/Article
January 11, 2011, previously published on January 10, 2011
On January 7, 2011, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations that would impose information collection and reporting requirements on US financial institutions with respect to bank deposit interest paid to non-US persons (the “2011...

 

Adobe PDFUS IRS Issues Preliminary FATCA Guidance Establishing Due Diligence Procedures and Information Reporting Rules for Foreign Financial Institutions
James R. Barry, Robert Z. Kelley, Donald C. Morris, Jonathan A. Sambur; Mayer Brown LLP;
Legal Alert/Article
September 17, 2010, previously published on September 16, 2010
On August 27, 2010, the US Internal Revenue Service (the “IRS”) published Notice 2010-60 (the “Notice”) containing preliminary guidance regarding implementation of the so-called FATCA rules.1 The HIRE Act, enacted on March 18, 2010, imposed new information reporting and...

 

Adobe PDFSignificant Revisions to US International Tax Rules
Rafic H. Barrage, James R. Barry, Kenneth Klein, Michael K. Marion, Arthur C. Walker; Mayer Brown LLP;
Legal Alert/Article
August 31, 2010, previously published on August 25, 2010
The Education Jobs and Medicaid Assistance Act of 2010 (Pub. L. No. 111-226) (the “Act”) became law on August 10, 2010. While the Act’s primary purpose is to provide financial assistance to US states for education and Medicaid spending, several international tax provisions were...

 

Adobe PDFProposed Legislation Permits Foreign Shareholders to Own Increased Percentage of Domestic REITs without Becoming Subject to FIRPTA
James R. Barry, Jeffrey M. Bruns, Anne Marie Konopack, William A. Levy; Mayer Brown LLP;
Legal Alert/Article
August 26, 2010, previously published on August 16, 2010
On July 30, 2010, the US House of Representatives passed H.R. 5901, the Real Estate Jobs and Investment Act of 2010, by a vote of 402 to 11. If it becomes law, this legislation would amend Section 897 of the Internal Revenue Code of 1986, as amended, which was enacted as part of the Foreign...

 


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