Matthew Kohley

Matthew Kohley

Patterson Belknap Webb & Tyler LLP

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Proposed Disregarded Entity Regulations: Potential Implications for Charities

On May 10, 2016, the Internal Revenue Service (“IRS”) published proposed regulations that would impose additional reporting and record-keeping requirements on domestic “disregarded entities” that are wholly owned (directly or...more

5/25/2016 - Charitable Organizations Disregarded Entities Foreign-Owned Corporations IRS Recordkeeping Requirements

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

5/19/2016 - Corporate Taxes Domestic Corporations Foreign-Owned Corporations Internal Revenue Code (IRC) IRS Reporting Requirements Tax Treaty

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

7/17/2014 - Credit Suisse DOJ Enforcement Enforcement Actions FBAR IRS Offshore Banks Offshore Funds OVDP Penalties Pre-Clearance Tax Penalties UBS

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

1/11/2013 - Alternative Minimum Tax American Taxpayer Relief Act Capital Gains Dividends FATCA Fiscal Cliff Foreign Earned Income Foreign Nationals Foreign Tax Income Taxes Itemized Deductions Payroll Taxes Personal Exemptions Tax Exemptions Tax Rates

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