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New U.S. Federal Income Tax Withholding Regulations On Cross-Border Equity Derivatives And Related Developments

Webinar: ID# 1023438
Recorded CD
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About This Course:
Under current law, withholding on dividend equivalents paid to non-U.S. persons is required only in a few instances.

Beginning in 2017, however, withholding will be required on virtually all financial products that reference U.S. equities and are held by non-U.S. persons.

Even exchange-traded options and futures will be affected by the new rules. Non-U.S. issuers of equity-linked financial products will be subject to the new qualified derivative dealer rules if they hold hedges when they issue such products.

The webinar will provide participants with a plain English, but in-depth, explanation of the new rules, market strategies for addressing the rules and an understanding of the withholding regime.

AGENDA

New Regulations on the Taxation of Dividend Equivalents Paid in Cross-Border Swaps and on Equity-Linked Instruments
  • Regulation Impacts on Management of Exchange-Traded Options, Structured Products and Swaps
  • When Do the Rules Apply?
  • When Do Transactions Need to Be Combined to Find Taxable Dividend Equivalents?
  • Withholding Tax Exception for Qualified Indices
IRS Temporary Regulations on Deemed Loans Embedded in Off-Market and Exchange-Cleared Swaps
  • Systems and Reporting Challenges to Market Participants
The New Qualified Derivative Dealer Rules
  • The QDD Regime
  • Who Does This Impact?
About The Presenter

Mark H. Leeds
  • Tax partner with the law firm of Mayer Brown LLP
  • Practice focuses on the tax consequences of a variety of capital markets products and strategies, including over-the-counter derivative transactions, swaps, tax-exempt derivatives, strategies for efficient utilization of tax attributes as well as advising on crossborder tax issues
  • Prior to joining Mayer Brown LLP he was a shareholder at another international law firm, and a managing director and senior tax counsel with Deutsche Bank AG in New York
  • At Deutsche Bank he led the Tax Counsel function within Group Tax of the Americas
  • Recipient of the 2015 Burton Award for Distinguished Legal Writing
  • Prior to joining Deutsche Bank he served as the general counsel of a credit derivative company and, prior to that he was a partner at Deloitte & Touche where he led the Capital Markets Tax Practice
  • Frequent writer on tax topics affecting the Capital Markets and also speaks on many topics
  • Began his professional career as a tax associate, first at Skadden Arps, and then at Weil Gotshal
  • .D. degree, magna cum laude, Boston University School of Law; B.A. degree in economics, cum laude, Binghamton University; LL.M degree in taxation, New York University
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New U.S. Federal Income Tax Withholding Regulations On Cross-Border Equity Derivatives And Related Developments
Available on CD format
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