General Business Finance & Banking Tax

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Complying with Regulation X §1024.17(k)(5) - Timely Disbursements from Escrow

As part of its 2014 Mortgage Servicing Rules, the Consumer Financial Protection Bureau (CFPB) issued §1024.17(k) of Regulation X, which is devoted to Escrow Accounts and the requirements for disbursements made from those...more

Changes on the Horizon? IRS Announces New Plans to Recharacterize Management Fee Waiver Arrangements

On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more

IRS Issues Proposed Regulations Relating to Disguised Payments for Services and Discussing Tax Treatment of Management Fee Waiver...

On Wednesday July 22, 2015, the Internal Revenue Service (“IRS”) issued Proposed Regulations (REG-115452-14) providing guidance to partnerships and partners as to whether an arrangement between a partnership and a service...more

Proposed Regulations Target Management Fee Waivers

In the Federal Register for July 23, 2015, the Treasury Department published proposed regulations regarding the circumstances under which partnership allocations and distributions will be treated as disguised payments for...more

Proposed IRS Regulations Target Management Fee Waiver Arrangements

On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more

New Proposed Treasury Regulations Focus on Management Fee Waivers

On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more

IRS Issues Proposed Regulations Addressing Fee Waivers

On July 22, 2015, the U.S. Department of the Treasury issued proposed regulations addressing the tax treatment of certain private equity management fee waivers. These new rules could result in many common management fee...more

Alert: IRS Issues Long-Awaited Proposed Regulations on Management Fee Waivers

On July 22, 2015, the Treasury Department and the IRS published proposed regulations (the "Proposed Regulations") that address the circumstances in which allocations or distributions made by a partnership to a partner that...more

Proposed Regulations on Disguised Payments for Services and Management Fee Waivers

On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

$10,000 in Cash Receipts? Heightened Penalties for Failure to File Form 8300 Within 15 Days

Any person who, in its trade or business, receives cash in the amount of more than $10,000 in a single transaction or a series of related transactions must file Form 8300, Report of Cash Payments Over $10,000, Received in a...more

The UK Summer Budget - Private Equity and Investment Management

The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

UK Summer Budget 2015: Osborne's 'Big Summer Budget' – the key measures impacting business

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

UK Summer Budget 2015

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

U.S. Perspective on Intercompany Cross-Border Loans – Follow Best Practices and Avoid Unintended Consequences

When funds are moved through a corporate group, whether to fund an acquisition or the working capital needs of an affiliate, the transfers may be recorded as book-entry advances and not documented or documented at a later...more

The China State Administration of Taxation releases working procedures for indirect transfer rules

In early February, the China State Administration of Taxation (SAT) issued Notice 71. This Notice superseded the provisions in relation to indirect share transfers under the well-known Circular 6982 and has become the key tax...more

Alabama 2015 Regular Session Legislative Summary: June 2015

The Alabama Senate adjourned sine die on Thursday, June 4, and the Alabama House of Representatives met for their last day on Thursday, June 11. Although the legislature passed a record-setting, $6 billion Education Trust...more

Australian Tax Alert: Investment Manager Regime (IMR) – Bill To Implement Element 3 Is Now Law

Tax and Superannuation Laws Amendment (2015 Measures No. 1) Bill 2015 (the Bill), containing the third element of the IMR, has been passed by the Australian Parliament and received Royal Assent on Thursday 25 June 2015. This...more

Tax Newsletter - March/April 2015 (China & Hong Kong)

In This Issue: The People's Republic of China: - China Tightens Tax Control Over Cross-Border Intercompany Payments - China Provides Further EIT Incentives For Integrated Circuit Industry - Expansion of...more

Special Focus: What The Insurance Industry Should Know About The IRS’s Campaign Against “Abusive” Micro Captives

Though in the midst of a stifling budget and personnel reduction, the United States Internal Revenue Service (“IRS”) recently announced an increased effort to curb what it sees as widespread abusive applications of so-called...more

Financial Services Quarterly Report - Second Quarter 2015: Countdown to 1 July 2015: Accessing China and Australia via Hong Kong’s...

On 1 July 2015, two significant developments in the Asian funds space will come into effect. Hong Kong’s Mutual Recognition of Funds Scheme (MRF) with the PRC will – for the first time – allow international managers to...more

IRS Releases New Proposed Issue Price Regulations

On June 23, 2015, the IRS released new proposed Treasury Regulations (the “2015 Proposed Regulations”) concerning the definition of “issue price” for purposes of arbitrage investment restrictions on tax-exempt bonds. The...more

Pensions News - May 2015

In This Issue: - Election Result - The Pensions Regulator - Case Law - Other News - On the Horizon - Excerpt from Election Result: Following the General Election on 7 May which resulted in a...more

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