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Capital Markets › Withholding Tax

A&O Shearman

The FASTER Directive—where are we now?

A&O Shearman on

After years of negotiation and technical debate, the European Union’s Faster and Safer Tax Relief of Excess Withholding Taxes Directive (“FASTER Directive”)—aimed at streamlining and harmonizing withholding tax (WHT) relief...more

Mayer Brown

Capital Markets Tax Quarterly - January 2020

Mayer Brown on

On December 16, 2019, the IRS released Notice 2020-2 (the “Notice”), which further extends the phase-in of regulations under Section 871(m) of the Code3 (the “Regulations”)4 and related provisions. Section 871(m) and its...more

Cadwalader, Wickersham & Taft LLP

Application of New Debt-Equity Regulations to Securitizations

Cadwalader, Wickersham & Taft LLP on

On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

Cadwalader, Wickersham & Taft LLP on

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 (collectively, the “new regulations”) that provide the rules for...more

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