Gerald Rokoff

Gerald Rokoff

DLA Piper

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IRS modifies and extends continuity safe harbor, clarifies other guidance for production tax credit eligibility

The IRS has released Notice 2016-31, which extends and modifies the “continuity safe harbor” for purposes of the “begun construction” requirement applicable to the renewable electricity production tax credit (PTC) under §45...more

6/14/2016 - Begun Construction Test Energy Projects Investment Tax Credits IRS Physical Work Test Production Tax Credit Renewable Energy Safe Harbors Solar Energy

Insurance 2015 year-end review and forecast for 2016

Our Year-End Review and Forecast for 2016 reviews some of the more notable events and trends in the insurance industry over the past 12 months. Our crystal ball is a bit clouded by the scale and speed of changes we see, but...more

3/4/2016 - Asia Australia Big Data Commercial General Liability Policies Complex Corporate Transactions Cybersecurity DOL EU Foreign Insurance Companies Insurance Industry Life Insurance NAIC Regulatory Agenda TRIA

Global Tax News - February 2016

The European Commission has released its highly anticipated anti-tax-avoidance package. The package, released January 28, 2016, contains proposed rules and recommendations to avoid aggressive tax planning within the...more

2/8/2016 - Audits BEPS Brazil Canada Currency Exchange Estate Tax EU European Commission FIRPTA International Tax Issues IP License Russia Software Tax Avoidance Tax Reform UK VAT

FIRPTA reform under the Protecting Americans from Tax Hikes Act of 2015: key points for non-US investors

Among the reforms and provisions in the Protecting Americans From Tax Hikes Act of 2015 are several important changes to the Foreign Investment in Real Property Tax Act of 1980 (commonly referred to as FIRPTA) that are...more

2/5/2016 - FIRPTA Investors Pension Funds Protecting Americans from Tax Hikes (PATH) Act REIT

IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

7/31/2015 - Fee Waivers Fund Managers Investment Funds IRS Partnerships Private Equity Private Equity Funds Profits Interests Safe Harbors Section 409A Section 457A U.S. Treasury

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

7/6/2015 - Corporate Taxes Financial Reporting GAAP Hedge Funds Insurance Industry Internal Revenue Code (IRC) Investment Funds IRS Offshore Companies Passive Foreign Investment Company Proposed Legislation Reinsurance SPVs Tax Deferral U.S. Treasury

District court finds that insurance premium excise tax does not apply to retrocession transactions

On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more

2/7/2014 - Casualty Insurance Excise Tax Federal Taxes Indemnity Insurance Reinsurance Retrocessional Claims

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