On September 21, the Treasury Department and the IRS issued Notice 2026-61, further delaying the full implementation of the withholding rules on dividend equivalent payments. The Notice extends the phase-in of regulations under Section 871(m) of the Code and related provisions until 2029.
We examine the guidance in the Notice and its implications in this
Masterclass | September 22, 2026
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Defined outcome products include a range of products designed to provide investors with some level of certainty (a “predictable” outcome if held for the specified period) usually based on a buffer, while providing equity market exposure. In recent periods, defined outcome ETFs have experienced particularly notable
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Join us for our defined outcome products series. Defined outcome products include a range of products designed to provide investors with some level of certainty (a “predictable” outcome if held for the specified period) usually based on a buffer, while providing equity market exposure. In
The U.S. government has been steadily tightening rules relating to who can benefit from clean energy incentives. The One Big Beautiful Bill Act (OBBBA) is the latest step, and it makes one thing crystal clear: if your company has ties to certain foreign governments, your access to federal tax credits could be at risk and
On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and experimental (R&E) expenditures, the limitation on interest deductibility under Section 163(j), state and local tax (SALT) deductions, expansion of the qualified small business stock
The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier version of this bill was passed by the US House of Representatives on May 22, 2025 (the “House version”). Our prior Legal
Our Convertible Bonds: An Issuer’s Guide is available to download. The guide has been updated to include a discussion relating to European and US issuers.
The convertible bond market has been active as companies refinance converts issued during the pandemic. Driven by a high interest rate environment and ongoing macroeconomic uncertainty, companies issued over $86
In Thomson Reuters’ Practical Law latest Q&A, Mayer Brown Capital Markets and Tax team provides a high-level overview of the main equity and debt markets/exchanges, and the main regulators and legislation that govern them. The Q&A also covers prospectus/main offering document requirements, together with any disclosure obligations and exemptions from the requirements to publish/deliver a
The US Department of the Treasury and the Internal Revenue Service recently issued long-awaited proposed regulations under Section 4501 of the Internal Revenue Code regarding the 1% stock buyback excise tax. The tax applies to stock repurchases and “economically similar transactions” undertaken by publicly traded US (and certain foreign) corporations beginning on January 1, 2023.
On December 27, 2022, the Treasury Department and the Internal Revenue Service (“IRS”) issued Notice 2023-7 (the “Notice”) describing proposed regulations Treasury intends to issue to address certain aspects relating to the application of a new corporate alternative minimum tax (“CAMT”)—a 15% tax on the adjusted financial statement income (“AFSI”) introduced by the Inflation Reduction