Creating a financial technology (fintech) firm comes with a host of tax considerations and implications. Decisions about the business’s structure, along with the location of both the business itself as well as its employees,...more
The Inflation Reduction Act of 2022, passed by the US Senate on August 7, 2022, will dramatically affect a range of climate change, healthcare, prescription drug pricing, and tax matters. With an investment of more than $400...more
Companies with coronavirus (COVID-19)-related losses and legacy liabilities may appreciate significant additional tax benefits from funding those legacy liabilities through a captive insurer before the end of this year. ...more
Final regulations applicable to controlled foreign corporations and their US shareholders, issued by the US Treasury under Code Section 956, generally follow previously proposed regulations but introduce two modifications: a...more
Dear Retail Clients and Friends:
The California Supreme Court recently ruled that consumers cannot file suit to force a retailer to seek a refund of sales taxes from the California tax agency absent a determination by the...more
The proposed modifications would create opportunities for enhanced CFC credit support.
On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more
Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders will be permitted to elect...more
New tax provisions have significant impact on structuring mergers and acquisitions.
In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions.
On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more
FDA’s guidance, which permits institutional review boards to waive informed consent for certain clinical investigations, may facilitate valuable personalized medicine research....more
The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event.
On August 6, the US Treasury...more
The new guidance addresses the New York sales and use tax treatment of cloud computing services.
Background -
On April 14, the New York State Department of Taxation and Finance (the Department) issued Advisory...more
The U.S. Supreme Court unanimously held that the Tax Injunction Act does not bar Direct Marketing Association’s federal court challenge to Colorado’s sales and use tax notice and reporting requirements....more
The IRS notice further eases, but does not delay, FATCA implementation.
On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more
Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms.
The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more
IRS modifies rules allowing the deferral method of accounting for advance payments received for the sale of gift cards that are redeemable by an unrelated party.
On July 24, the Internal Revenue Service (IRS) released an...more
IRS notice postpones FATCA withholding by six months and revises other key deadlines.
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