An Overview of the SEC’s Recently Adopted Exchange-Traded Funds (ETF) Rule
In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more
On July 12, 2024, Treasury and the IRS published proposed regulations (the “Proposed Regulations”) that would identify certain basket contract transactions as well as transactions substantially similar thereto as “listed...more
On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more
Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more
The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more
Implementing the DOL Fiduciary Rule - Background - On June 9, 2017, key provisions of the fiduciary rule adopted by the Department of Labor (“DOL”) will become applicable for most broker-dealers, as well as many...more
The Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced its first 13 issue-based campaigns on January 31, 2017. As discussed in a prior Eversheds Sutherland Legal Alert, these...more