On May 20, 2014, the New York State Bar Association Tax Session issued a Report on Proposed Regulations under Section 871(m) of the Internal Revenue Code of 1986.  The report addresses proposed regulations that the Internal Revenue Service issued in December 2013 concerning withholding on equity-linked financial instruments that reference U.S. stocks.^[1]  The report, available here, was co-authored by Orrick partner Peter J. Connors.

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^[1] A past issue of Derivatives in Review (available here) also reported on those proposed regulations.