Administrative Agency Tax Finance & Banking

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Conflating tax law and trust law: The strange case of Ciampa v. Bank of America.

Under the Internal Revenue Code, an Individual Retirement Account (IRA) may be a trust. See 26 U.S. Code § 408(a). Or it may be a custodianship. See sub-section (h) to §408. Here is sub-section (h) verbatim: FOR PURPOSES...more

IRS Limits Ability of REITs to Obtain Private Letter Rulings on Tax-Free Spin-Off Transactions

In the recently released Revenue Procedure 2015-43, the Internal Revenue Service (“IRS”) announced that it no longer will issue private letter rulings with respect to certain tax-free spin-offs where, immediately after the...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

MoFo New York Tax Insights - Volume 6, Issue 7 - July 2015

In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal...more

House Bill 15-1348-Urban Renewal – Frequently Asked Questions

H.B. 15-1348 was signed by the Governor on May 29. The bill enacts several changes related to urban renewal authorities and tax increment financing for such authorities including governance changes and changes related to how...more

Nevada Legislature Changes Procedure For Certain Bonds (AB 170)

AB 170, a bill amending NRS 350.020 passed by the Nevada Legislature, was signed by the Governor on June 11, 2015. It amends subsection 3 of NRS 350.020 which specifies the procedures to be followed to issue general...more

Department of Justice Reprioritizes Asset Seizure in Structuring Cases But Risks Remain

On December 23, 2014, the United States Attorney for the Eastern District of North Carolina filed a Complaint for Forfeiture In Rem seeking to forfeit $107,702.66 belonging to Lyndon McLellan, the owner of L&M Convenient Mart...more

Expect MDOR Audit Delays After the July 4, 2015 Holiday

Governor Charlie Baker’s recent plan to trim the number of Massachusetts employees was recently signed into law. According to published reports, more than half of all employees at the Massachusetts Department of Revenue are...more

FinCEN Announces First Civil Enforcement Action Against Virtual Currency Exchanger

Continuing its aggressive anti-money laundering enforcement agenda, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced yesterday that it had commenced the first-ever civil enforcement action...more

CFPB and Navajo Nation Partner in UDAAP Action Against Companies Involved in Alleged Tax Refund Scheme

On April 14, the CFPB along with the Navajo Nation jointly announced an enforcement action against two companies and their respective owners (Defendants) for running an alleged tax-refund scheme, marking the CFPB’s “first...more

Pensions Alert UK: April 2015 reforms: Final regulations made

The introduction of the DC flexibilities announced in last year’s Budget is now only a matter of days away, and in recent weeks various sets of regulations have been made in final form which will come into force on 6 April...more

MoFo New York Tax Insights - Volume 6, Issue 4 - April 2015

In This Issue: - State Tribunal Affirms Decision Imposing Sales Tax on Information Services - Appellate Division Upholds Applicability of Sales Tax to Environmental Testing and Monitoring Services - Bulk...more

BSI Account Holders Now Face 50 Percent Penalty On All Undisclosed Offshore Accounts

On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more

BSI Is First Bank to Reach Resolution in DOJ’s Program for Swiss Banks

BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more

Tax Law Blog: 529A ABLE Account Guidance (Sort Of....)

In December 2014, the Achieving a Better Life Experience (ABLE) Act was passed by the US Senate and House and approved by the President. The ABLE Act will amend Section 529 of the Internal Revenue Code to create a tax-free...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

EU Passes New Council Directive to Implement “EU-FATCA" - The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more

Public Finance Update: New Clean Renewable Energy Bonds: IRS Notice 2015-12 Application Submission and Requirements

The Internal Revenue Service (“IRS”) recently released Notice 2015-12 (the “Notice”), which solicits applications for allocations of the approximately $1.4 billion remaining available amount of national bond volume limitation...more

ALJ: New York NOL Deduction Does Not Apply When Tax Is Not Paid on Income Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently determined that a banking corporation was not required to hypothetically use a net operating loss (NOL) deduction to decrease its entire net...more

State/Local Bond Proposals in Administration's 2016 Budget

Several proposals affecting tax-exempt bonds were included in the Obama Administration's Budget for FY 2016. As usual, the overall budget proposal has immediately been declared DOA by political pundits. Nonetheless, taking...more

Delaware Enacts Unclaimed Property Legislation That Addresses Some (But Not All) Holder Concerns

The Delaware Legislature appears to have heard some of the complaints of the unclaimed property community. Delaware Governor Jack Markell signed Senate Bill 11, which is based on the recommendations of the Delaware Task Force...more

Banking Corporation Not Required to Hypothetically Use New York NOL Deduction When Tax Is Paid on Asset Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in Matter of TD Holdings II, Inc., DTA No. 825329 (N.Y. Div. Tax App. Jan. 22, 2015), that a banking corporation is not required to...more

Commercial Restructuring & Bankruptcy Alert - February 2015

In This Issue: - Minority Holders Gain Leverage Through Recent Interpretation of Trust Indenture Act - New Jersey Joins Number of States Creating Specialty Business Courts - Credit Bid Rights Bolstered in...more

MoFo New York Tax Insights - Volume 6, Issue 2

In This Issue: - Governor Cuomo Releases 2015-16 Executive Budget, Including New York City Corporate Tax Reform - New Commissioner of Taxation and Finance - ALJ Holds That Husband Changed His Domicile to...more

Pension News - December 2014

In This Issue: - Budget Reforms - Pension Protection Fund - Department for Work and Pensions - Legislation - Case Law - HMRC - Public service pension schemes - On the Horizon - Excerpt from...more

Luxleaks - The next level

Until recently, the Luxemburg Government had resisted the European Commission's attempts to disclose the beneficiaries of tax rulings. It had even taken the information injunction to the EU Court of Justice. This has now...more

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