William R. Pomierski William R. Pomierski

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William (Bill) R. Pomierski focuses his practice on the taxation of financial products and capital markets transactions, as well as on executive compensation matters. He is a former chair of the Firm’s Executive Compensation Practice Group. Bill advises clients on the federal income tax implications of a variety of domestic, cross-border and global financial products and related transactions. Read William Pomierski's full bio.

IRS Issues Long-Awaited Initial Guidance under Section 162(m)


By , , and on Aug 27, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

On August 21, 2018, the IRS issued guidance regarding recent statutory changes made to Section 162(m) of the Internal Revenue Code. Overall, Notice 2018-68 strictly interprets the Section 162(m) grandfathering rule under the Tax Cuts and Jobs Act. Public companies and other issuers subject to these deduction limitations will want to closely consider this guidance...

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Proposed Regulations Address Applicable Adjustments to Stock and Stock Rights under Code Section 305(c)


By on Dec 8, 2016
Posted In IRS Guidance, Uncategorized

In an apparent response to coordination questions raised by comments to proposed regulations under Code Section 871(m) (relating to certain cross-border dividend equivalent payments), the US Department of the Treasury issued proposed regulations on April 12, 2016, (the Proposed Regulations) addressing deemed distributions of stock and stock rights under Code Section 305(c). Among other stated...

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Discussion Draft of Modernization of Derivatives Tax Act


By on Aug 24, 2016
Posted In Transfer Pricing Resource, Uncategorized

On May 18, 2016, Senate Finance Committee Ranking Member, Senator Ron Wyden, released a financial product tax reform discussion draft that, if adopted, would significantly alter the current tax rules with respect to financial products (derivatives), as well as the tax treatment of certain non-derivative positions that are offset by derivatives. The discussion draft is...

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