Shawn M. Willette

(303) 292-7788
Partner
(303) 292-7799 Fax
Shawn.Willette@KutakRock.com
February 9, 2017
"Variation margin (VM) rules," which apply to U.S. swap dealers, are proposed to go into effect on March 1 in the U.S. To find out more about the protocols and possible exceptions to them, read our client alert.
Client Alert
January 26, 2017

On January 17, 2017 the Internal Revenue Service issued Rev. Proc. 2017-13.

Client Alert
July 26, 2016

On July 18, 2016, the Treasury Department published final regulations (the “Final Regulations”) on arbitrage restrictions under section 148 of the Internal Revenue Code of 1986, as amended.

Client Alert
September 20, 2013

On September 16, 2013, the IRS published proposed regulations (the Proposed Regulations) in the Federal Register covering several areas relating to tax-exempt bonds, including the determination of the issue price of such bonds. It is important to note that these Proposed Regulations are, for the most part, not yet in effect. While issuers may elect to apply certain portions of the Proposed Regulations, the general rule is that the Proposed Regulations will impact bonds issued on or after 90 days following the publication of final regulations in the Federal Register. For the time being, we will continue to apply the existing regulations (the Existing Regulations) unless it is advantageous to apply the Proposed Regulations to new transactions.

Client Alert
April 9, 2013
As noted in our March 28, 2013 Client Alert, on March 15, 2013 the federal Commodity Futures Trading Commission (CFTC) issued an advisory which stated that all swap participants needed to obtain a Legal Entity Identifier number (also known as an LEI or CICI) prior to April 10, 2013. While the language of the CFTC’s advisory was unambiguous, it conflicted with a prior CFTC regulation which provided participants in existing swaps until October 7, 2013 to obtain a CICI (although anyone entering into a new swap on or after April 10 must have a CICI when entering into the new swap). Although some CFTC staff have reportedly orally acknowledged the October 7 date is correct, the CFTC has not yet officially clarified the advisory.
Client Alert
March 28, 2013

As part of the reporting regime under the Dodd-Frank Wall Street Reform and Consumer Protection Act, all parties to swap agreements (Swap Participants), including municipal issuers, need to have Legal Entity Identifier numbers (also known as LEIs or CICIs) that are used when dealers report swaps. Note this requirement even applies with respect to certain swaps that already have been terminated to the extent they were in effect on or after April 25, 2011. Read this client alert for more information about the need to apply for or certify LEIs.

Client Alert
February 17, 2011

The purpose of this memorandum is to describe the status of certain tax provisions subsequent to the end of calendar year 2010 that are of interest to the attorneys and clients of Kutak Rock LLP’s public finance practice.

Client Alert