Michael Hirschfeld

Michael Hirschfeld

Dechert LLP

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Publicly Traded Partnership Proposed Regulations

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

6/24/2015 - Corporate Taxes Double Taxation Energy Projects Energy Sector Fracking IRC IRS Limited Partnerships Master Limited Partnerships Mining Natural Gas Oil & Gas Partnerships Passive Activity Proposed Regulation Publicly-Traded Companies Qualifying Income Research and Development

US Energy Excise Tax Proposed Legislative Changes

Federal excise taxes imposed on natural gas, propane and other alternative fuels can significantly add to their cost and can create a disincentive to their use compared with more traditional fuels such as diesel and gasoline,...more

4/16/2015 - Alternative Fuel Tax Parity Act Alternative Fuels Energy Policy Energy Tax Incentives Excise Tax Fuel Tax Liquid Natural Gas Natural Gas Oil & Gas Propane Proposed Legislation

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more

3/13/2015 - Corporate Taxes Double Taxation Funding Internal Revenue Code IRS Mineral Exploration Oil & Gas Partnerships Private Letter Rulings PTPs Publicly-Traded Companies Section 7704

Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For...more

12/24/2014 - Cross-Border FATCA FFI Intergovernmental Agreements OECD

Hong Kong’s Long-Awaited FATCA Announcement

With deadlines looming, Hong Kong’s government announced on May 9th a much-anticipated agreement with the United States regarding the U.S. Foreign Account Tax Compliance Act (FATCA). Without this intergovernmental agreement...more

6/26/2014 - Banking Sector FATCA FATCA Timeline Hong Kong Intergovernmental Agreements IRS U.S. Treasury

FATCA: IRS Relaxes Impending Deadlines for FATCA Compliance, but does not Eliminate the Need to Comply

Compliance with the Foreign Account Tax Compliance Act (“FATCA”) has been causing a great deal of anxiety as the July 1, 2014, start date for FATCA withholding grows nearer. Compliance has been partially hampered by the lack...more

5/8/2014 - FATCA Filing Deadlines International Tax Issues IRS

OECD Sets Out Ambitious Global Plan to Tackle Tax Fairness Issues

The Organisation for Economic Co-operation and Development (OECD) issued an “Action Plan” to tackle “Base Erosion and Profit Shifting” (“BEPS”) on 19 July 2013. The concept of BEPS covers a range of international tax...more

7/24/2013 - Enforcement Actions Fairness Hearings G20 OECD Tax Rates Tax Reform

Revised Timeline for Implementing FATCA

Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more

7/16/2013 - Bank Accounts Banks FATCA FFI IGAs Internal Revenue Code IRS U.S. Treasury

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more

3/27/2013 - Asset Management Due Diligence FATCA FFI Intergovernmental Agreements IRS U.S. Treasury Withholding Requirements

Tax Credits for Alternative Energy Manufacturing Facilities Just Announced

In order to foster investment and job creation in clean energy manufacturing, the American Recovery and Reinvestment Act of 2009 included a tax credit for investments in manufacturing facilities for clean energy technologies....more

2/15/2013 - American Recovery and Reinvestment Act Clean Energy Clean Tech Investment Tax Credits IRS Manufacturing Facilities Tax Credits

Significant Changes Made in Final FATCA Regulations

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

2/11/2013 - Collateralized Debt Obligations Due Diligence FATCA FFI Agreements Foreign Financial Accounts GIIN Intergovernmental Agreements Investment Funds IRS Portal Required Documentation Sponsoring Entities U.S. Treasury Withholding Requirements

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