The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more
The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more
Final U.S. Treasury regulations under Section 446 of the Internal Revenue Code of 1986, as amended (the “Code’), providing for the use of the net asset value (“NAV”) accounting method for transactions in money market fund...more
7/26/2016
/ Accounting Methods ,
Excise Tax ,
Final Rules ,
Floating NAV ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Company Act of 1940 ,
IRS ,
Money Market Funds ,
NAV ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more
The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more
Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more
Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more
6/13/2014
/ Deferred Compensation ,
Equity Compensation ,
Executive Compensation ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Private Equity Funds ,
SAR ,
Section 457A ,
Stock Options ,
Tax Planning