Stephen Lessard

Senior Associate

New York


Read full biography at www.orrick.com
Stephen Lessard, an associate in Orrick's New York office, is a member of the Tax Group. Steve focuses his practice on the taxation of debt and equity offerings, cross-border transactions, tax controversy, and municipal finance. He also has experience counseling nonprofit organizations on federal tax law and corporate governance. 

Prior to joining Orrick, Steve was a Surface Warfare Officer in the U.S. Navy.

Posts by: Stephen Lessard

IRS Proposes to Revise the Treatment of Nonperiodic Payments

 

On May 8, 2015, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) issued proposed and temporary regulations (the “Regulations”) relating to the treatment of notional principal contracts (“NPCs”) with nonperiodic payments.[1] The Regulations are designed to resolve questions that have arisen with the enactment of Dodd-Frank. The Regulations are a fundamental change in the treatment of NPCs. The rules apply to NPCs entered into on or after November 4, 2015, but taxpayers may apply the rules to NPCs entered into before November 4, 2015. The Regulations package also includes regulations under section 956 of the Internal Revenue Code of 1986 (the “Code”).

While the Regulations are designed to resolve issues, many unanswered questions remain. READ MORE