INVESTORS 871(m) Follow-Up Letter

Below is the final version of the follow-up letter regarding dividend equivalents from sources within the United States under Section 871(m) of the Internal Revenue Code that was submitted to the Treasury.

TAX POLICY: Senate Finance Hearing on Inversions

On Tuesday, July 22, 2014, the Senate Finance Committee held a hearing entitled “The U.S. Tax Code: Love It, Leave It or Reform It!” The panel of witnesses included officials from the U.S. Treasury Department and the Organisation for Economic Co-operation and Development (OECD), as well as members of academia, an economist with PricewaterhouseCoopers and a senior editor from Fortune.

TAX POLICY: IRS Issues Final Mixed Straddle Rules

We wanted to let you know that the Internal Revenue Service issued final regulations on Thursday, July 17, 2014, concerning the treatment of unrealized investment gains and losses in so-called mixed straddle deals. A “mixed straddle” is a combination of positions in futures contracts with offsetting gains and losses. The final rule requires taxpayers to account for the gains and losses from the futures contracts as though their subsequent offset investments don't exist. The IRS said the final rules will be effective July 18, 2014, but will only apply to straddles established after Aug. 18, 2014.

Tax InBrief: June 30, 2014

Read monthly updates on tax-related industry headlines and Congressional and agency actions.
UPDATED AS OF Friday, June 27, 2014

Tax InBrief: May 2014

Read monthly updates on tax-related industry headlines, congressional and agency actions, announcements, rulemaking, and letters received.
UPDATED AS OF Wednesday, May 28, 2014