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Derivatives Internal Revenue Service Proposed Regulation

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Holland & Knight LLP

IRS Proposes to Classify Basket Contracts as a Tax Avoidance Scheme

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on July 11, 2024, issued proposed regulations that would classify certain basket contract transactions as listed transactions. Taxpayers and material advisers participating in...more

Eversheds Sutherland (US) LLP

Proposed regulations issued under section 1256 with respect to foreign currency options

Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more

Holland & Knight LLP

Treasury Department, IRS Issue Proposed Rules on Tax Impact of Transition from Libor

Holland & Knight LLP on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more

A&O Shearman

Tax Guidance on the Transition From Interbank Offered Rates Under OIRA Review

A&O Shearman on

On August 28, 2019, the U.S. Department of Treasury submitted proposed regulations on the tax consequences related to the phased elimination of interbank offered rates (the “Proposed Regulations”) to the Office of Management...more

Goodwin

IRS Addresses RIC Qualification Matters Related to Derivatives and Use of Blocker Corporations

Goodwin on

On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more

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