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Capital Markets Tax Quarterly - Volume 2, Issue 2
Q2 2019 started out with a great deal of hope in the world of capital markets taxation.
United States
6 Aug 2019
IRS Issues Proposed Regulations Regarding Withholding Under Section 1446(f)
On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)
United States
15 Jul 2019
Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
Treasury Adds Color To Grecian Repeal – Proposed Regulations Implement New Section 864(C)(8) For Sale Of Partnership Interests By Foreign Partners
On December 20, 2018, the US Department of Treasury and the IRS released proposed regulations under Section 864(c)(8) of the Code on the treatment of a foreign partner's transfer of an interest in a partnership...
United States
14 Jan 2019
Capital Markets Tax Quarterly
Welcome to Mayer Brown's Capital Markets Tax Quarterly (CMTQ). This is a new publication for Mayer Brown's Tax practice, so let us explain what we're about.
United States
23 Oct 2018
FATCA Certifications Delayed And Other Welcomed Guidance Issued
On January 19, 2016, the US Internal Revenue Service issued Notice 2016-08, which announced the intention to amend the Treasury regulations promulgated under chapter 4 of the Internal Revenue Code.
United States
22 Jan 2016
Process Is Its Own Reward: The IRS Modifies FATCA Effective Dates & Interim Compliance Standards
On May 2, 2014, there were exactly 60 days until withholding and due diligence rules under the Foreign Account Tax Compliance Act ("FATCA") became effective. Notwithstanding the fact that the US Internal Revenue Service (the "IRS") has promulgated well over 1,000 pages of proposed, temporary and final rules, substantial uncertainty continues to exist over how the rules can be competently administered.
United States
7 May 2014
Important Foreign Account Tax Compliance Act (FATCA) Development For Withholding Agents And Foreign Financial Institutions
Domestic payers of certain types of US-source income and foreign financial institutions (FFIs) must determine whether their payees and account holders are compliant with the Foreign Account Tax Compliance Act (FATCA) and ..
United States
4 Apr 2014
IRS Issues Corrections To FATCA Regulations
On September 9, 2013, the Internal Revenue Service issued corrections to the final regulations implementing the Foreign Account Tax Compliance Act, issued in January 2013.
United States
9 Oct 2013
An "Available Upon Request" GRA Is A Willful Failure
Since 1986, the U.S. Treasury Department regulations promulgated under section 367(a) of the Internal Revenue Code have provided a reasonable cause exception for gain recognition agreement compliance failures.
United States
17 Sep 2013
It’s Always A Day Away: The IRS Postpones FATCA Withholding
Through an odd set of events, the oldest of the authors of this Legal Update attended opening night of the original production of "Annie" in 1977.
United States
17 Jul 2013
The IRS Issues Final FATCA Regulations
On January 17, 2013, the Internal Revenue Service (IRS) released 544 pages of final regulations implementing the provisions of the Foreign Account Tax Compliance Act.
United States
28 Jan 2013
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