White Paper

Comeback Victory - The IRS Issues Final Dividend Equivalent Regulations

 
“Chuck Tanner, the unsinkable manager of the Pittsburgh Pirates baseball team, said he had three secrets to managing the 1979 World Series championship team, after staring down a three games- to-one deficit. The first was patience. The second was to be patient. And the third most important secret was patience. There is no doubt that the Internal Revenue Service (the “IRS”) took a page from Chuck’s playbook in developing final and temporary regulations implementing the dividend equivalent rules for Section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). This Code section treats dividend equivalents paid to a non-US person in the same manner as actual dividends in such a person’s hands. After two attempts at drafting regulations and listening to significant industry blowback, on September 16, 2015, the IRS promulgated the most thoughtful set of rules yet. And as anyone who has been following this saga knows, it has taken more than a dollop of patience. After a brief background discussion, this article summarizes, in decision-tree format, when the final regulations will apply and provides some observations about their operation.”

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Mark H Leeds is a tax partner with the law firm of Mayer Brown. Mark’s professional 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 cross-border tax issues.

Faculty

Mark H. Leeds

Mark H. Leeds

Mayer Brown LLP

Agenda

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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