Tax Partner Quoted on Repeal of Exceptions for Foreign-Targeted Bearer Debt

Today's Tax Press | March.07.2012

This article, about the Internal Revenue Service's repeal of exceptions for foreign-targeted bearer debt, quotes New York tax partner Peter Connors.

"The temporary use of reg. section 1.871-14(e) is quite a positive surprise," said Peter J. Connors. "Most people did not think any relief was possible."

Connors said that generally the notice "looks excellent." He said it was a positive development to see that the term "dematerialized" includes those physical securities that were immobilized in a clearing system. "That will be more consistent with market practice," said Connors.