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

Gain a better understanding of the reporting requirements of U.

S. dividend equivalents.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 topic 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.

Runtime: 94 minutes
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Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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?
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Webinar

This course was last revised on December 15, 2016.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • GA CLE 1.7
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MO CLE 2.0
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Mark H. Leeds

Mark H. Leeds

Mayer Brown LLP

  • 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
  • J.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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Product ID: 399998
Published 2016
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