Abigail Wolf

Abigail Wolf

Foley Hoag LLP

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Partnership Audit Regime Shakeup

The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more

2/5/2016 - Audits Bipartisan Budget IRS Limited Liability Companies Opt-Outs Partnership Agreements Partnerships TEFRA

Changes on the Horizon? IRS Announces New Plans to Recharacterize Management Fee Waiver Arrangements

On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more

7/31/2015 - Capital Gains Clawbacks Deferred Compensation Fee Waivers Fund Sponsors Internal Revenue Code (IRC) IRS Management Fees Partnership Agreements Partnerships Profits Interests Significant Entrepreneurial Risk (SER)

FBAR Filing Deadline Approaching

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2014 must electronically file with the U.S. Treasury...more

5/13/2015 - FBAR Filing Deadlines FinCEN Foreign Financial Accounts

2014 Tax Reporting

Don’t Forget About Your Foreign Financial Assets - U.S. citizens, resident aliens and certain non-resident aliens who held any interest in “specified foreign financial assets” at any point during 2014 may be required...more

4/7/2015 - FBAR Foreign Bank Accounts Foreign Financial Assets IRS Required Forms Tax Returns

FBAR Filing Deadline Approaching

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2013 must electronically file with the U.S. Treasury...more

5/19/2014 - FBAR Filing Deadlines FinCEN Foreign Investment Offshore Funds OVDP Reporting Requirements U.S. Treasury

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