On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022 (the “Act”), which was signed into law by President Biden on August 16, 2022. Alongside sweeping changes to energy, environmental and...more
8/26/2022
/ Alternative Minimum Tax ,
American Rescue Plan Act of 2021 ,
Business Losses ,
CARES Act ,
Corporate Taxes ,
Excise Tax ,
Fair Market Value ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Publicly-Traded Companies ,
Shareholders ,
Stock Repurchases ,
U.S. Treasury
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
8/13/2020
/ Capital Gains ,
Carried Interest ,
Fund Managers ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more
12/19/2018
/ Common Reporting Standard (CRS) ,
FATCA ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
IRS ,
Mutual Funds ,
Non-Residents ,
OECD ,
Private Funds ,
Proposed Amendments ,
Regulatory Burden ,
U.S. Treasury ,
Withholding Requirements
The U.S. Department of the Treasury (the “Treasury”) and the U.S. Internal Revenue Service (the “IRS”) have issued a new installment of proposed regulations under the centralized partnership audit regime included in the...more
Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more
On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more
2/11/2013
/ Collateralized Debt Obligations ,
Due Diligence ,
FATCA ,
Foreign Financial Accounts ,
Global Intermediary Identification Number (GIIN) ,
Intergovernmental Agreements ,
Investment Funds ,
IRS ,
Portal ,
Required Documentation ,
U.S. Treasury ,
Withholding Requirements