Christopher Cawley

Christopher Cawley

Foley Hoag LLP

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FATCA Compliance Deadlines for December 2014

What Managers of U.S. and Non-U.S. Investment Funds Should Do Today - FATCA went into effect on July 1, 2014 and will be phased in through January 1, 2017. During that period, varying compliance deadlines apply to...more

12/4/2014 - FATCA FATCA Timeline Foreign Investment Fund Fund Managers Investment Funds Reporting Requirements

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

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

4/8/2014 - FATCA Timeline Foreign Entities Intergovernmental Agreements IRS Tax Evasion

FATCA: Crunch Time (April 25th Deadline is Imminent)

Every foreign entity must take steps immediately to determine whether FATCA will apply to it and, if so, whether FATCA registration will be required by April 25, 2014....more

3/31/2014 - Deadlines FATCA

New Proposals to Tax Carried Interest as Ordinary Income Garner Bipartisan Support

On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more

3/7/2014 - Corporate Taxes Hedge Funds Incentives Income Taxes Performance Incentives Tax Reform

FATCA: With Deadlines Looming, the Time to Act is Now

On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more

2/27/2014 - Banks Deadlines FATCA FFI Foreign Banks Income Taxes

Massachusetts “Tech Tax” Abatement Applications Due December 31, 2013

In September 2013, Massachusetts enacted legislation to retroactively repeal the extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and software modification services...more

12/19/2013 - Business Taxes Corporate Taxes Department of Revenue

100 Percent Tax Exemption for Gain on Certain Qualified Small Business Stock Expiring at Year End

In January 2013, Congress enacted legislation that could provide certain investors who acquire qualified small business stock (“QSBS”) before the end of 2013 with a significant tax benefit. In effect, the gains realized from...more

12/13/2013 - Alternative Minimum Tax Income Taxes Investors Qualified Small Business Stock Tax Exemptions Year-End Planning Year-End Tax Planning

Massachusetts "Tech Tax" Repealed

On September 27, 2013, Massachusetts Governor Deval Patrick signed legislation to retroactively repeal the recent extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and...more

10/3/2013 - Computer-System Design/Software Services Sales & Use Tax

Massachusetts "Tech Tax" Payment and Reporting Due Dates Deferred

In light of last week’s news that Massachusetts lawmakers intend to retroactively repeal the controversial “tech tax”, the Massachusetts Department of Revenue (“MDOR”) yesterday announced that it is deferring the September 20...more

9/18/2013 - Corporate Taxes Department of Revenue Repeal Reporting Requirements

Massachusetts Lawmakers Plan to Repeal the New “Tech Tax” on Computer System Design and Software Modification Services

On September 12, 2013, Massachusetts legislators announced their intention to repeal (with retroactive effect) the recent expansion of the 6.25 percent Massachusetts sales and use tax to certain types of previously untaxed...more

9/16/2013 - Business Taxes Corporate Taxes Repeal Software Developers Technology

FATCA Registration Now Available

On August 19, 2013, the IRS began to accept applications for registration under FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, by requiring foreign financial institutions (“FFIs”),...more

8/26/2013 - FATCA IRS Registration Tax Evasion

FATCA Timeline and Registration Delayed

On July 12, 2013, the IRS issued new guidance regarding FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers. In particular, the IRS (1) revised certain elements of the timeline for FATCA...more

7/16/2013 - Corporate Taxes FATCA FFI IGAs IRS

FATCA Compliance for Investment Fund Managers, Part Three

Offshore Master with U.S. and Offshore Feeders - This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more

6/27/2013 - FATCA Fund Managers Investment Funds IRS Offshore Funds

FBAR Filing Deadline Imminent

Reports Due Before the End of June - Every U.S. person that had a financial interest in, or signature authority over, a foreign financial account during 2012 must file U.S. Treasury Form TD F 90-22.1, Report of Foreign...more

6/21/2013 - Deadlines FBAR Foreign Bank Accounts IRS

FATCA Compliance for Investment Fund Managers, Part Two

This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more

5/13/2013 - Compliance FATCA Investment Funds Offshore Funds Registration

President Obama's 2014 Budget Proposes to Tax Carried Interest as Ordinary Income

Yesterday, President Obama issued his Administration’s Fiscal Year 2014 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more

4/12/2013 - Barack Obama Carried Interest Incentives Income Taxes

Information Reporting for US Entities with Interests in Foreign Financial Assets Delayed

Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more

4/4/2013 - FATCA IRS Reporting Requirements Specified Foreign Financial Asset

FATCA Compliance for Investment Fund Managers Part One

U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

4/2/2013 - Compliance FATCA Fund Managers Investment Funds IRS Offshore Funds Tax Evasion Withholding Tax

Congress Extends the 100% Tax Exemption for Gain on Certain Qualified Small Business Stock, With Retroactive Effect, Through 2013

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”). Among its provisions, the Act extends a tax benefit whereby capital gains from the sale or exchange of certain...more

1/16/2013 - Alternative Minimum Tax American Taxpayer Relief Act Capital Gains Fiscal Cliff Gain Exclusion Income Taxes Net Investment Income Qualified Small Business Stock Tax Exemptions

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