On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA).
Congress enacted FATCA in 2010 as part of...more
Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more
On July 24, 2013, the U.S. Court of Appeals for the First Circuit held that a private equity fund sponsored by Sun Capital Advisors constituted a “trade or business” for purposes of ERISA multiemployer pension withdrawal...more
The first congressional proposals to revamp partnership and S corporation taxation in connection with anticipated tax reform have surfaced. Framed as two alternatives, both options suggest significant, and, in the case of one...more
On January 24, 2013, Rep. Dave Camp (R-Mich), the chairman of the House Ways and Means Committee, released a “discussion draft” of a bill relating to the taxation of derivatives and other financial products (the Discussion...more
On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more