On August 26, 2020, the SEC adopted several changes to expand the definition of an “accredited investor.” For the first time, a new category will enable natural persons to qualify as accredited investors based upon their...more
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
8/25/2020
/ Arms Length Transactions ,
Capital Gains ,
Capital Investments ,
Carried Interest ,
Fund Managers ,
Holding Periods ,
Income Taxes ,
Investment Adviser ,
Investment Management ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Popular ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
As we reported in our previous client alert, "Federal and State Tax Actions in Response to COVID-19," the IRS has extended until July 15, 2020, the deadline for filing income, gift and GST tax and information returns, and...more
We believe the following tax developments are of particular interest to our clients.
Tax Return Filing Extensions -
The 2019 federal income tax return filing deadline is extended to July 15, 2020, for individuals,...more
4/1/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
Financial Stimulus ,
Net Operating Losses ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Relief
Every five years, the Bureau of Economic Analysis (BEA) requires "U.S. Reporters" of certain foreign business interests to submit surveys on Form BE-10. This year the surveys, or requests for extension, must be submitted by...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES) Act authorizes the Small Business Administration to make loans to allow "small businesses" to continue their payroll, and provides for cancellation of the loans...more
One provision of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) involves a "real estate" tax break, which is actually much broader and applies to many taxpayers, and may require the filing of amended tax...more
Historically, we have advised clients that it is no less advantageous, from a federal income tax perspective, to acquire a partnership interest (including a membership interest in an LLC taxed as a partnership) than it would...more
Currently, individual taxpayers who itemize their deductions can deduct real property taxes paid that year. Under both the House and Senate tax reform bills, the property tax deduction would be capped at $10,000. If that cap...more
Beginning in 2018, most partnerships (including LLCs and other arrangements treated as partnerships for tax purposes) will be subject to a new “centralized partnership audit regime.” The volume of Internal Revenue Service...more
It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more
9/7/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Comment Period ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Financial Institutions ,
FinCEN ,
High Net-Worth ,
Investors ,
Legal Entities ,
Private Trust Companies
The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...more
On June 1, 2016, the SEC sent a warning to general partners of private investment funds (including private equity funds, hedge funds, venture capital funds and leveraged buyout funds) by entering into a settlement agreement...more
Every five years, the U.S. Bureau of Economic Analysis of the U.S. Department of Commerce (BEA) conducts a “benchmark” survey regarding U.S. direct investment abroad by country and industry. The purpose of the survey is to...more