Jill Darrow

Katten Muchin Rosenman LLP

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IRS Issues New Partnership Audit Procedures

Included as a revenue offset in the budget legislation (H.R. 1314) signed by President Obama are provisions that simplify the procedure for the Internal Revenue Service to audit and collect adjustments from partnerships. The...more

11/11/2015 - Audits Hedge Funds IRS Partnerships U.S. Treasury

Corporate and Financial Weekly Digest - Volume X, Issue 43

SEC/CORPORATE - SEC Proposes Amendments to Rules 147 and 504 - On October 30, the Securities and Exchange Commission proposed amendments to modernize: (1) Rule 147, promulgated under the Securities Act of 1933...more

11/9/2015 - Enforcement Actions MiFID II Rule 147 Section 504 SEFs UK

US Withholding Tax on Dividend Equivalent Payments Under Swaps

The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on swaps and other financial instruments that are linked to US equities. These...more

10/20/2015 - Dividends ISDA Swaps U.S. Treasury Withholding Tax

Corporate and Financial Weekly Digest - Volume X, Issue 40

BROKER-DEALER - FINRA Requests Comment on Revised Price Disclosure Information Standards for Corporate and Agency Debt Securities - The Financial Industry Regulatory Authority issued a regulatory notice...more

10/19/2015 - AIFM AIFMD Broker-Dealer CFTC Commodities Exchange Act Debt Securities Disclosure Requirements Dividends EU European Commission Financial Regulatory Reform FINRA Investment Funds NFA No-Action Relief OCC Proposed Regulation Swaps Withholding Tax

IRS Addresses RIC Asset Diversification Requirements

On September 14, the Internal Revenue Service (IRS) issued final regulations under Internal Revenue Code Section 851 clarifying that control groups under the regulated investment company (RIC) rules may consist of two...more

10/1/2015 - Asset Diversification Final Rules Internal Revenue Code (IRC) Investment Funds IRS RICs Safe Harbors Subsidiaries

SEC Proposes Liquidity Management Rules for Mutual Funds and ETFs

On September 22, the Securities and Exchange Commission proposed a comprehensive package of rule reforms designed to enhance effective liquidity risk management by open-end funds, including mutual funds and exchange-traded...more

9/30/2015 - Asset Class Board of Directors Comment Period ETFs Independent Director Investment Company Act of 1940 Investment Funds Liquidity Risk Management Rule Mutual Funds NAV Proposed Regulation Registration Statement SEC

Corporate and Financial Weekly Digest - Volume X, Issue 37

SEC/CORPORATE - SEC Advisory Committee on Small and Emerging Companies Makes Recommendations - On September 23, the Securities and Exchange Commission Advisory Committee on Small and Emerging Companies (Advisory...more

9/28/2015 - ACH Payments Asset Diversification Banking Sector Broker-Dealer CFTC Derivatives Derivatives Clearing Organizations Emerging Growth Companies FDIC Financial Conduct Authority (FCA) Finders Investment Funds IRS Mutual Funds Registration Requirement Rule 147 SEC SEC Advisory Committee Supervision U.S. Treasury UK

IRS Considers Whether Management Fees of an LLC Are Subject to Self-Employment Tax

A recent response by the Internal Revenue Service Chief Counsel (CCA) to an inquiry from one of its field office agents addressed the question of whether management fees earned by an investment manager organized as a limited...more

9/23/2014 - Investment Management IRS Limited Liability Companies Limited Partnerships Management Fees Self-Employment Tax

Corporate and Financial Weekly Digest - Volume IX, Issue 37

In this issue: - Council of Institutional Investors Issues Report on Board Evaluation Disclosure - FINRA Revises Proposal to Adopt Consolidated FINRA Rule 2231 - IRS Considers Whether Management Fees of...more

9/22/2014 - Broker-Dealer CFTC Corporate Governance Dodd-Frank EU FINRA Insider Trading Institutional Investment IRS Limited Liability Companies Margin Requirements Swaps

IRS Ruling Creates Opportunities for Tax Savings by Companies With Substantial Real Estate Assets

On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more

8/21/2014 - Corporate Taxes Income Taxes IRS Mortgage REITS REIT Telecommunications

IRS Issues Pronouncement on Virtual Currencies

On March 25, the Internal Revenue Service (IRS) issued Notice 2014-21 (notice) containing guidance and frequently asked questions relating to virtual currencies such as bitcoins. Among other clarifications, the notice states...more

4/4/2014 - Bitcoin IRS Virtual Currency

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