Client Alert
| March 22, 2010
HIRE Act Introduces Significant U.S. Tax Law Changes
On March 18, 2010, U.S. President Barack Obama signed into law the Hiring Incentives to Restore Employment Act (the "HIRE Act"). The Act incorporates a number of revenue raisers, including provisions that will (i) re-source "dividend equivalent" payments under certain equity swaps and stock loans over stock of U.S. corporations, (ii) impose stringent due diligence and reporting requirements on non-U.S. financial institutions in respect of foreign accounts owned by certain U.S. persons and U.S.- owned foreign entities, and (iii) affect certain obligations issued in bearer form by both U.S. and non-U.S. issuers. The tax changes introduced by the HIRE Act are very significant and will severely impact non-U.S. persons, especially financial institutions and funds.
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This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
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