A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets.
This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength.
Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations.
Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
On December 4, 2013, the Treasury Department and the Internal Revenue Service released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal withholding tax on certain equity-linked payments.
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On December 4, 2013, the Treasury Department and the Internal
Revenue Service (the "IRS") released new final and
proposed regulations under section 871(m) of the Internal Revenue
Code regarding the imposition of US federal withholding tax on
certain equity-linked payments. Under the final regulations, swap
payments made prior to January 1, 2016 will continue to be subject
to the existing sourcing rules contained in section 871(m). Under
the proposed regulations, beginning January 1, 2016, payments made
under swaps and certain other financial instruments with respect to
US equities that have a "delta" of 0.7 or greater would
be treated as US source income under section 871(m) and, thus,
potentially subject to US withholding tax. The proposed regulations
raise many difficult questions relating to tax policy, economic
impact on markets and companies and administrability, among
others.
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