Searching Content indexed under Withholding Tax by Cadwalader, Wickersham & Taft LLP ordered by Published Date Descending.
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Using Irish Treaty Funds To Avoid US Taxes In Direct Lending
Private debt funds raised more than $100 billion for the fourth consecutive year in 2018,[1] and reached their highest level of fundraising on record during the first half of 2019.[2]
United States
10 Oct 2019
Tax Update: IRS Trims Back FATCA
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA.
United States
20 Dec 2018
UK Budget 2018 – Key Tax Measures
The Chancellor of the Exchequer delivered the United Kingdom ("UK") Budget for 2018 on 29 October 2018.
United States
6 Nov 2018
Federal Register: Treasury Proposes Regulations On Opportunity Zones
An IRS and U.S. Treasury Department ("Treasury") notice of proposed rulemaking relating to the new Opportunity Zone tax incentive was published in the Federal Register.
United States
2 Nov 2018
IRS Extends Effective Date And Phase-In Period For Dividend Equivalent Rules
The Internal Revenue Service ("IRS") delayed implementing certain rules that are intended to prevent non-U.S. persons from using derivative instruments to avoid U.S. withholding tax on U.S. equities.
United States
27 Sep 2018
IRS Extends Phase-in Period For Section 871(m) Withholding Regulations
The anti-abuse rule will continue to apply during the phase-in years.
United States
15 Aug 2017
Cadwalader Attorneys Discuss Phase-In Of Rules Concerning Dividend Equivalent Payments Under IRS Section 871(M)
In a Cadwalader memorandum, Cadwalader attorneys discussed IRS Notice 2016-76, which phases in the application of rules concerning withholding on dividend equivalent payments under IRS section 871(m).
United States
12 Dec 2016
IRS Phases In Section 871(m) Dividend Equivalent Withholding
On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m).
United States
9 Dec 2016
Application Of New Debt-Equity Regulations To Securitizations
Unlike the proposed regulations issued in April, the new regulations do not apply to debt issued by foreign securitizations that are treated as corporations for U.S. tax purposes, such as most foreign CLOs.
United States
2 Nov 2016
Cadwalader Attorneys Review IRS Proposal To Revise QI Agreement
Cadwalader attorneys reviewed an IRS proposal to revise the qualified intermediary agreement.
United States
12 Jul 2016
Proposed QI Agreement Addresses Cascading Withholding On Dividend Equivalents
As discussed in a prior Clients & Friends Memo, section 871(m) of the Internal Revenue Code imposes withholding on "dividend equivalents" paid on derivatives that reference U.S. equity securities.
United States
11 Jul 2016
The PATH Act
The PATH Act extends or makes permanent over 50 separate provisions that had expired or were set to expire.
United States
5 Jan 2016
New 871(M) Regulations Finalize Dividend Equivalent Payment Withholding Rules For Equity Derivatives
On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code that provide the rules for withholding on "dividend equivalent payments" on derivatives that reference U.S. equity securities.
United States
9 Oct 2015
Taxation Without Authorization: The Proposed "Dividend Equivalent" Withholding Regulations Under Section 871(m)
The currently proposed regulations under section 871(m) threaten to impose "dividend withholding" on a broad range of swaps, options, futures contracts, and other financial contracts.
United States
24 Sep 2014
Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives
On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed on U.S. equity derivatives.
United States
24 Dec 2013
The Final FATCA Regulations: Applications To Foreign Investment Vehicles
On January 17, 2013, the Internal Revenue Service issued final regulations that provide guidance on the "Foreign Account Tax Compliance Act".
United States
7 Feb 2013
U.S. Treasury Department Releases Model FATCA Intergovernmental Agreements
On July 26, the U.S. Treasury Department released two model intergovernmental agreements that will provide residents of signatory countries with an alternative withholding and reporting regime to that imposed under the "Foreign Account Tax Compliance Act" ("FATCA") provisions contained in sections 1471 through 1474 of the Internal Revenue Code.
United States
15 Aug 2012
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