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

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 Publicly-Traded Companies

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

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 Foreign Financial Accounts GIIN Intergovernmental Agreements Investment Funds IRS Portal Required Documentation U.S. Treasury Withholding Requirements

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