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Notional Principal Contracts (NPCs) and equity-linked instruments (ELIs)

Effective date revised for recently issued dividend equivalent regs

Effective date revised for recently issued dividend equivalent regs

Correcting amendment to TD 9734 (Dec. 4, 2015) IRS has issued a correction to T.D. 9734 which changes the effective date of certain regs pertaining to the treatment of dividend equivalents under Code Sec. 871(m). The regs affected by the correction pertain to specified notional principal contracts (NPCs) and equity-linked instruments (ELIs). Background. In general, nonresident […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney