William P. Zimmerman

William P. Zimmerman

Morgan Lewis

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Latest Publications


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

Treasury, IRS Extend Certain FATCA Transitional Rules

IRS Notice postpones several key deadlines and provides other relief. On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more

9/28/2015 - Amended Regulation FATCA FATCA Timeline Foreign Financial Institutions (FFI) GIIN Grandfathered Obligations Intergovernmental Agreements IRS Pro Rata Allocation Rule U.S. Treasury Withholding Requirements

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 (IRC) Intra-Group Transactions Investment Management IRS Management Fees Proposed Regulation Safe Harbors Taxable Distributions 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

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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