Richard Zarin

Richard Zarin

Morgan Lewis

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IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

7/28/2015 - Enterprise Risks Fee Waivers Internal Revenue Code Intra-Group Transactions Investment Management IRS Management Fees Proposed Regulation Safe Harbors Taxable Distributions U.S. Treasury

IRS Proposes Curtailing “Next-Day Rule” in Corporate Acquisitions

Are you a day late? - On March 5, the Internal Revenue Service (the IRS) published proposed regulations (REG-100400-14, RIN 1545-BM14) (the Proposed Regulations) that would place strict new guidelines on the “next-day...more

3/18/2015 - Corporate Taxes IRS Proposed Regulation

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

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

New Accounting Rules for Gift Cards Redeemable by Unrelated Entities

IRS modifies rules allowing the deferral method of accounting for advance payments received for the sale of gift cards that are redeemable by an unrelated party. On July 24, the Internal Revenue Service (IRS) released an...more

7/30/2013 - Accounting Gift-Cards IRS Retail Market Tax Deferral

Treasury Revises FATCA Implementation Timeline

IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...more

7/16/2013 - Delays FATCA FFI Foreign Banks IGAs IRS Tax Reform 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

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