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  • Fact Sheet: US Treasury Issues Final Earnings Stripping Regulations

    Date 13/10/2016

    On April 4, Treasury issued proposed regulations to address earnings stripping by strengthening the tax rules distinguishing between debt and equity.  After extensive engagement with businesses, tax experts, the public, and lawmakers, today we are announcing the final regulations.  
    After a corporate inversion, multinational corporations often use a technique called earnings stripping to minimize U.S. taxes by paying deductible interest to the new foreign parent or one of its foreign affiliates in a low-tax country.  This commonly-used technique can generate large interest deductions without requiring a company to finance new investment in the United States.  The new regulations restrict the ability of corporations to engage in earnings stripping by treating financial instruments that taxpayers purport to be debt as equity in certain circumstances. They also require that corporations claiming interest deductions on related-party loans provide documentation for the loans, similar to the common practice for third-party loans.  The ability to minimize income tax liabilities through the issuance of related-party financial instruments is not, however, limited to the cross-border context, so these rules also apply to related U.S. affiliates of a corporate group.

  • Thomson Reuters Launches Specialized Intraday Pricing Service Directed At Money Market Instruments - New Service Provides 24/5 Updated Evaluated Pricing For Money Market Instruments, Readies Customers For SEC Money Market Fund Reform

    Date 13/10/2016

    Thomson Reuters has introduced a specialized intraday evaluated pricing service for money market instruments, providing evaluated pricing that is updated throughout the global business day for public and other non-public short-term instruments. The new service helps mutual fund managers meet demands for intraday net asset value (NAV) calculations, as well as for increased investor disclosure and transparency requirements that have emerged as part of the U.S. Securities and Exchange Commission’s (SEC) money market fund reform.

  • US Treasury’s Issues Final Earnings Stripping Regulations To Narrowly Target Corporate Transactions That Erode U.S. Tax Base - Regulations Distinguish Between Debt And Equity

    Date 13/10/2016

    Today, the U.S. Department of Treasury and the Internal Revenue Service (IRS) issued final regulations to address earnings stripping. This action will further reduce the benefits of corporate tax inversions, level the playing field between U.S. and non-U.S. businesses, and limit the ability of companies to lower their tax bills through transactions involving debt that do not support new investment in the United States. These regulations also require large corporations claiming interest deductions to document loans to and from their affiliates, just as businesses of all sizes do when they borrow from unrelated lenders. The rules were proposed in April along with temporary anti-inversion regulations.  The final rules announced today are the product of extensive public comment and engagement.

  • Remarks By US Treasury Secretary Jacob J. Lew On A Press Conference Call Regarding Announcement On Earnings Stripping

    Date 13/10/2016

    Today, Treasury is announcing our final earnings stripping regulations. Earnings stripping is commonly used to minimize taxes after an inversion, and a contributing factor to the erosion of the U.S. corporate tax base.

  • SEC: Company To Pay Penalty For Stock Picking Game That Was An Unregistered Swap

    Date 13/10/2016

    The Securities and Exchange Commission today announced that a New York-based company has agreed to pay a $50,000 penalty for illegally offering complex derivatives products to retail investors through mobile phone games that were described as “fantasy sports for stocks.”