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ANALYSIS: New IRS Audit Guidelines Target Equity Swaps with Non-U.S. Counterparties

February 3, 2010 in Daily Tax Report · Leave a Comment 

For more than 20 years, applicable Treasury regulations have provided that income from an equity swap, including dividend equivalent payments, is foreign-source income in the hands of a non-U.S. person who did not enter into the swap in connection with the conduct of a U.S. trade or business…

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