A profound effect on family controlled businesses may be in store when proposed Treasury Regulations under Section 2704 of the Internal Revenue Code come to pass. Under the new regulations, taxpayers would be precluded from...more
On May 10, 2016, the Treasury Department issued proposed regulations (the Proposed Regulations) which enable the Internal Revenue Service (IRS) to collect certain information about domestic disregarded entities with a single...more
The Internal Revenue Service (IRS) recently announced that starting in 2015, taxpayers who filed their 2014 federal tax return with an address in Florida, Georgia, or Washington, D.C. are eligible to obtain an "identity...more
On January 17, 2013, the IRS released final regulations for the Foreign Account Tax Compliance Act ("FATCA") to be effective on January 28, 2013. Enacted by Congress in 2010, FATCA targets non-compliant U.S. taxpayers using...more
The U.S. Department of Treasury ("Treasury") recently released its second model agreement (the "Model II Agreement") for countries to implement the Foreign Account Tax Compliance Act ("FATCA"). FATCA requires foreign...more