Michael Greenberg

Michael Greenberg

DLA Piper

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Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

7/7/2015 - Corporate Taxes Financial Reporting GAAP Hedge Funds Insurance Companies Investment Funds IRC IRS Offshore Companies Passive Foreign Investment Company Proposed Legislation Reinsurance SPVs Tax Deferral U.S. Treasury

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

7/6/2015 - Corporate Taxes Financial Reporting GAAP Hedge Funds Insurance Companies Investment Funds IRC IRS Offshore Companies Passive Foreign Investment Company Proposed Legislation Reinsurance SPVs Tax Deferral U.S. Treasury

Bitcoin is property, not currency, IRS says – Notice leaves many open questions about convertible virtual currencies

The Internal Revenue Service has joined several other jurisdictions in publishing guidance regarding the income tax consequences of certain convertible virtual currency transactions. IRS Notice 2014-21ii clarifies that...more

4/4/2014 - Bitcoins IRS Virtual Currency

FATCA regulations updated but deadlines loom

The US Department of the Treasury and the Internal Revenue Service have released what they refer to as the “last substantial package of regulations” necessary to implement the Foreign Account Tax Compliance Act (FATCA). ...more

3/13/2014 - Deadlines FATCA IRS U.S. Treasury

District court finds that insurance premium excise tax does not apply to retrocession transactions

On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more

2/7/2014 - Casualty Insurance Excise Tax Federal Taxes Indemnity Insurance Reinsurance Retrocessional Claims

IRS releases long-awaited draft FFI Agreement and previews updates to FATCA regulations

The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA). ...more

11/7/2013 - FATCA FFI IGAs IRS U.S. Treasury Withholding Tax

International Tax News - July 2013

OECD RELEASES “BEPS” ACTION PLAN – A SWEEPING INTERNATIONAL TAX EFFORT TO COMBAT BASE EROSION AND PROFIT SHIFTING - The OECD’s Committee on Fiscal Affairs has published its Action Plan to address Base Erosion and...more

8/2/2013 - G20 International Tax Issues OECD Tax Reform

Think you know your PFIC status? Think again: application of the look-through rules

The IRS has released Private Letter Ruling 201322009, which responds to a request for clarification on the proper application of certain “look-through” rules for purposes of determining whether a foreign corporation is a...more

7/31/2013 - Corporate Taxes Foreign Investment IRS Passive Foreign Investment Company Private Letter Rulings Subsidiaries

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