IRS Amends Temporary Regulations Under Section 871(m)
Orrick’s Tax team issued an alert on amendments to the Temporary Treasury Regulations that extend the definition of “specified notional principal contract” set forth in Section 871(m)(3)(A) to payments made before January 1, 2014.
Please read before sending e-mail.
Please do not include any confidential, secret or otherwise sensitive information concerning any potential or actual legal matter in this e-mail message. Unsolicited e-mails do not create an attorney-client relationship and confidential or secret information included in such e-mails cannot be protected from disclosure. Orrick does not have a duty or a legal obligation to keep confidential any information that you provide to us. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.
By clicking "OK" below, you understand and agree that Orrick will have no duty to keep confidential any information you provide.