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Amendments to New York LLC Transparency Act Delay Effective Date, Among Other Changes

New York Governor Kathy Hochul last month signed into law amendments to the recently enacted New York LLC Transparency Act (as amended, the “NYLTA”), extending the NYLTA’s effective date from December 21, 2024, to January 1,...more

Federal District Court in Alabama Rules Corporate Transparency Act Unconstitutional … But Don’t Dismiss It Yet!

On March 1, 2024, the U.S. District Court of the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional because it “exceeds the Constitution’s limits on the legislative branch” and...more

The IRS Announces Employee Retention Tax Credit Voluntary Disclosure Program: Why You May Want to Take a Look

It’s no secret. Lots of people made poor decisions about their eligibility for the employee retention credit (“ERC”), which was passed by Congress to help businesses weather the pandemic-induced economic downturn. Apart from...more

Private Equity and Hedge Funds Take Note: The Tax Court Says Limited Partners Must Pay Self-Employment Taxes

In a decision that will come as potentially bad news to many private equity and hedge funds, on November 28, 2023, the U. S. Tax Court opined in Soroban Capital Partners LP versus Comm’r that limited partners in a limited...more

Corporate Transparency Act Will Soon Impose New Disclosures to FinCEN

Beginning on January 1, 2024, the Corporate Transparency Act (the “CTA”) will impose a new obligation on many business entities formed or registered to do business in the United States to disclose their “beneficial owners”...more

The BR Privacy & Security Download: April 2022

Welcome to this month's issue of The BR Privacy & Security Download, the digital newsletter of Blank Rome’s Privacy, Security & Data Protection practice. We invite you to share this resource with your colleagues and visit...more

IRS Announces September 2018 End to Offshore Voluntary Disclosure Program

The Internal Revenue Service (“IRS”) announced it will close the highly successful Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018, which presumably will be the final date for taxpayers to submit a...more

Individual Tax Reform under the New Tax Law

On December 20, 2017, Congress passed its comprehensive tax reform bill, the Tax Cuts and Jobs Act (“the Act” or “the Bill”), which was signed into law by President Trump on December 22, 2017. The Bill represents one of the...more

Traps for the Unwary under California Law: How Good Deals Can Go Bad

California law has the potential to produce unintended consequences in real estate transactions. Below are a few of the legal “gotchas” that deal makers should keep in mind in transactions where California law...more

Overview of IRS Penalties for Individuals with Foreign Bank Accounts and Investments

Earlier this spring, the Internal Revenue Service ("IRS") Large Business and International Division identified several "campaigns" or areas where it plans to focus its audit resources. One campaign involved taxpayers who...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

IRS Criminal Investigation Division Announces New Priorities

At the ABA Section of Taxation’s 2017 May Meeting, Erick Martinez, the IRS Criminal Investigation Division’s Director of Field Operations – Northern Area, provided insight into the Division’s current priorities and...more

5/19/2017  /  Criminal Investigations , IRS

IRS Announces Plans to Move Forward with Passport Revocation Program

U.S. citizens who owe more than $50,000 in unpaid federal taxes are at substantial risk of having their U.S. passports revoked within the next few months. In December 2015, Congress enacted legislation requiring the IRS to...more

Application of Net Investment Income Tax to Section 453A Interest

Although the Internal Revenue Service (IRS) has not directly addressed this matter, interest accruing from installment agreements sales under Internal Revenue Code (IRC) section 453A is likely not included in net investment...more

9th Circuit: Online Poker Accounts Not Reportable on FBAR

On July 21, 2016, the Ninth Circuit in United States v. Hom, No. 14-16214 D.C. No. 3:13-cv-03721-WHA (9th Cir. 2016), determined that a taxpayer who held an online poker account with PokerStars and PartyPoker was not required...more

Congress Passes Protecting Americans from Tax Hikes (Path) Act of 2015, Making Many Tax Extenders Permanent

Action Item: The recently enacted PATH Act contains key tax provisions for businesses and individuals alike, including permanently expanding Section 179 of the Internal Revenue Code; extending the availability of...more

BE-10 Report: The Overlooked International Reporting Form -The June 30 Deadline is Fast Approaching

The Bureau of Economic Analysis (“BEA”), an agency of the U.S. Department of Commerce, is currently conducting a benchmark BE-10 survey that requires the filing of a BE-10 report by any U.S. person that directly or indirectly...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

6/26/2014  /  FATCA , FBAR , FinCEN , IRS , Popular , Tax Evasion

IRS Releases Bitcoin Guidance; May Have A Chilling Effect On Virtual Currency

Last week, the IRS released IRS Notice 2014-21 (the “Notice”), its first guidance on the income tax treatment of virtual currency, including, bitcoin. A copy of the notice can be obtained at...more

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