News & Analysis as of November 15, 2024

Derivatives

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Knowing Me, Knowing You! Using Private Derivatives in Personal Tax Planning

Gerald Nowotny - Law Office of Gerald R.... on 8/7/2024

I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more

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

A&O Shearman on 9/3/2019

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

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

Akin Gump Strauss Hauer & Feld LLP on 10/8/2018

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime

Proskauer - Tax Talks on 2/8/2016

Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more

After Months of Anticipation, Final FATCA Regulations Released

Morrison & Foerster LLP on 1/30/2013

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act (“FATCA”). ...more

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