Richard LaFalce

Richard LaFalce

Morgan Lewis

Contact  |  View Bio  |  RSS

Latest Publications

Share:

FinCEN Extends Filing Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2017 to file the Report of Foreign Bank and Financial Accounts....more

6/22/2016 - Corporate Officers FBAR Filing Deadlines FinCEN Foreign Bank Accounts Reporting Requirements SEC Time Extensions

IRS Issues Temporary and Proposed Regulations Focused on REIT/RIC Conversion Transactions

The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more

6/13/2016 - C-Corporation Corporate Conversions IRS Proposed Regulation Protecting Americans from Tax Hikes (PATH) Act Registered Investment Companies (RICs) REIT Spinoffs U.S. Treasury

IRS Offers Tax Guidance Relating to Money Market Fund Rules

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

5/24/2016 - Diversification Requirements Floating NAV Income Taxes Insurance Industry Internal Revenue Code (IRC) IRS MMF Money Market Funds Registered Investment Companies (RICs) RICs SEC

FBAR Proposed Regulations Expand Both Filing Exemption and Reporting

On March 1, the Financial Crimes Enforcement Network (FinCEN) issued proposed regulations that revise and clarify certain provisions in the rules regarding the filing of Reports of Foreign Bank and Financial Accounts (FBAR)....more

3/7/2016 - Exemptions FBAR FinCEN Foreign Financial Accounts Reporting Requirements

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

1/28/2016 - EU European Court of Justice (ECJ) Foreign Tax IRS Popular Redeterminations RICs Tax Credits Tax Refunds

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs. On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more

1/6/2016 - FIRPTA Foreign Investment Internal Revenue Code (IRC) Pension Funds Protecting Americans from Tax Hikes (PATH) Act Real Estate Investments Registered Investment Companies (RICs) REIT SEC Shareholders Spinoffs

IRS Delays Effective Date for New Regulations on Embedded Loans in Swaps

The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more

10/15/2015 - Comment Period Debt Financing Dodd-Frank Exceptions Income Taxes IRS Loans Proposed Regulation SIFMA Swaps Tax Exempt Entities U.S. Treasury

FinCEN Again Extends Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more

1/27/2015 - FBAR FinCEN Foreign Bank Accounts IRS SEC

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

The IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more

5/8/2014 - Banks Enforcement FATCA FFIs Foreign Banks International Tax Issues IRS

What Does the IRS Bitcoin Ruling Mean for Virtual Currency?

Because Bitcoin is fungible and greatly fluctuates in value on a daily basis, Bitcoin users will need to track their cost basis for each Bitcoin obtained and determine whether they have gain or loss on the subsequent exchange...more

4/24/2014 - Bitcoin Foreign Currency IRS Legal Perspectives Need to Know Virtual Currency

Initial FATCA Registration/Withholding Dates Draw Near

Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms. The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more

4/11/2014 - FATCA FATCA Timeline FFI IRS

FinCEN Announces Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2015 to file the Report of Foreign Bank and Financial Accounts....more

1/14/2014 - Extensions FBAR Filing Deadlines FinCEN U.S. Treasury

FinCEN Announces Third Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

1/7/2013 - FBAR FinCEN Foreign Banks IRS SEC

13 Results
|
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×