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In Wake of the Panama Papers, Treasury Proposes New Reporting Requirements for Foreign-Owned Legal Entities

On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a news conference May 6, President Obama addressed recently announced rules and proposed regulations intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

Partnership Audit Changes and Their Effect on Operating Agreements

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015. The Bipartisan Budget Act of 2015 contained several significant changes to the procedural rules for federal income tax audits and the...more

FinCEN Issues Final Rules for Customer Due Diligence Requirements

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more

UK Finance Bill 2016: Royalty Withholding Tax

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

Form 5472 Reporting by Foreign Owned Disregarded Entities Established in the U.S. - Coming Soon!

Presently, a domestic single member LLC, and other similar single owner entities, absent a check-the-box election to the contrary, are disregarded for almost all U.S. tax purposes. Presently, a foreign owner of such...more

Energy Tax Law Alert: IRS Rules That Payment for Intertie Constitutes Taxable Contribution in Aid of Construction

The IRS has issued a private letter ruling concluding that the reimbursement by a solar electric generator of an electric distribution company’s costs to construct an intertie is a contribution in aid of construction under...more

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

FinCEN Finalizes Beneficial Ownership Identification Rules

As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more

Key Economic Incentives for Businesses Considering a Florida Location

The State of Florida offers economic incentives to businesses that are thinking about locating—or relocating—in Florida. These incentives target corporate headquarters and certain high growth industries. In addition, many...more

Lease Receipts Subject to Business Privilege Taxes After All

The Pennsylvania Supreme Court recently reversed a 2014 Commonwealth Court decision in which the Commonwealth Court had ruled that the Local Tax Enabling Act (“LTEA”) bars local taxing jurisdictions from imposing business...more

MoFo New York Tax Insights - Volume 7, Issue 5

Retroactive Application Of 2010 Statutory Amendment Permitted By Tribunal - Reversing the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal has upheld the constitutionality of retroactively...more

NYC Extends Tax Credit Available to Biotech Companies

In late 2015, New York City Mayor Bill de Blasio signed into law a three-year extension of NYC’s biotechnology tax credit. The credit, which was set to expire on January 1, 2016, is now available through December 31, 2018....more

Partnerships Must Respond to New Audit Rules

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

New Proposed Regulations Increase Scrutiny on Related-Party Debt

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

China Customs authorities enhance monitoring of intercompany prices and royalty payments

China’s General Administration of Customs (GAC) has released an amendment to the Import and Export Declaration Documents Standards. Among many changes, the Amendment now requires Chinese entities with importing and exporting...more

The Panama Papers: Managing Corporate Risk and Uncertainty

On April 3, 2016, it became public that an anonymous source had leaked 11 million confidential documents, known as the “Panama Papers,” belonging to the Panama-headquartered international law firm Mossack Fonseca. As more of...more

The Panama Papers: Taking a New Look at an Old Problem

On April 3, 2016, the International Consortium of Investigative Journalists (“ICIJ”) published more than 11.5 million documents connected to Mossack Fonseca, a Panama law firm that helped establish offshore financial...more

Panama Papers: Looking Below the Headlines

The media loves a scandal. In the banking and compliance world, the latest scandal to hit the media was the Panama Papers. The Panama Papers is surprising in scope – Panama has become the favorite financial haven for money...more

The Global Spotlight on Transparency: Renewed Focus on Tax and Financial Regulatory Enforcement in Singapore

The global spotlight on transparency in tax and financial reporting has come to Singapore, signalling cause for renewed focus on compliance for investors and global business operators. On 6 April, the Singaporean Ministry of...more

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

Early Stage Investment Tax Incentives Bill Introduced

As an update to our Legal Insight of December 2015 'New Tax Incentives for Early Stage Investment', on 16 March 2016 the Turnbull Government introduced legislation providing significant tax incentives to promote local and...more

Treasury Department Issues Temporary and Proposed Regulations to Curb Inversions and Earnings Stripping

On April 4, 2016, the Internal Revenue Service and the Treasury Department issued temporary and proposed regulations formalizing rules contained in Notices 2014-52 and 2015-79 limiting corporate tax inversions, as well as...more

MTC Arm’s-Length Adjustment Service (Part II): “An Expression of Grief, Pity, or Concern”

Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more

CRA Provides Update on Efforts to Combat Tax Evasion

Following the release of the “Panama Papers” and the Canadian federal government’s budget announcement that additional resources will be directed to the CRA to collect existing tax debts and combat tax evasion, the CRA has...more

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