Finance & Banking Tax

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Financial Services Quarterly Report - Second Quarter 2015: OECD Discussion Draft on BEPS: Funds’ Treaty Access under Threat

The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more

Labour Fund Reporting Requirements Enacted

The Income Tax Act was recently amended to enact unprecedented and potentially onerous public disclosure obligations on labour organizations and investment funds in which labour organizations or persons represented by a...more

Changes in the UK Tax Treatment of Carried Interest

In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more

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

Clinton Outlines Her Capital Gains Rate Hike

Following up on my post from last week, presidential candidate Hillary Clinton has now provided more specific information on her proposed capital gains rates hike. For high income filers (couples making at least $465,000...more

Proposed Regulations Issued On Management Fee Waivers

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more

Treasury Department and IRS Release Proposed Regulations on Management Fee Waivers

On July 22, 2015, the Treasury Department and the IRS released proposed regulations regarding fee-waiver arrangements commonly used by private investment funds. If finalized, the new rules would recharacterize certain...more

Tax Planning When Investing in Distressed Assets

Can private equity firms unwittingly trigger a tax when they invest in distressed assets? A: All taxpayers, including private equity firms, can trigger a tax when investing in distressed assets. This can occur when a...more

When the Fifth Amendment Privilege Doesn't Work-Tax Cases

A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. ...more

This Week In Securities Litigation

The SEC filed three actions following-up on its settled proceeding against Oppenheimer for selling millions of shares of unregistered penny stocks. Each individual settled with the agency. In addition, the Commission brought...more

Lawsuit by U.S. Presidential Candidate Challenges the Constitutionality of FATCA

Senator Rand Paul, R-Ky., along with six current and former U.S. citizens living abroad, filed a lawsuit, July 14, in the U.S. District Court for the Southern District of Ohio challenging the constitutionality of the Foreign...more

IRS Determination Letter Program for Qualified Retirement Plans to Be Significantly Curtailed

In Announcement 2015-19 (Announcement), the Internal Revenue Service (IRS) has indicated that it is eliminating the staggered five-year determination letter (DL) remedial amendment cycles for individually designed...more

Private Equity and Hedge Fund Managers Take Caution - Proposed Treasury Regulations Threaten Management Fee Waivers

On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more

The IRS Tosses Plan Sponsors a Curveball: New Guidance Throws Out One Method of Pension Plan De-Risking

In recent guidance, the IRS surprised plan sponsors with its plan to prevent them from using one means of “de-risking” their defined benefit pension plans to reduce their pension plan liabilities. In Notice 2015-49, the IRS...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

Revamping U.S. Taxation of Multinational Corporations?

The Obama administration and top lawmakers are in discussions regarding a potential overhaul of how the United States taxes U.S. multinational corporations. Topics under consideration include eliminating the U.S. approach of...more

Summer Budget 2015––Carried Interest: Abolition of Base Cost Shift

On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more

CRA: Bitcoins may be Specified Foreign Property

The CRA recently provided its views on whether digital currency, including Bitcoins, are considered “specified foreign property” under the foreign property reporting rules in section 233.3 of the Income Tax Act. Under...more

FinCEN Issues Geographic Targeting Order to Combat Stolen Identity Tax Refund Fraud in South Florida

On July 13, FinCEN issued a Geographic Targeting Order (GTO) requiring check cashers in two South Florida counties to strengthen identification requirements for customers cashing certain Federal tax refund checks. According...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

Good Bets by a 401(k) Plan Sponsor to Avoid Liability

I don’t gamble because I don’t like to lose and that’s a big problem about gambling because people do lose. I stopped playing Powerball and Mega Millions. The last time I ever bet on a sport was betting a friend $10 on the...more

IRS Guidance on FBAR Penalties

On May 13, 2015, the IRS issued interim guidance to its examiners regarding penalties for failure to timely file the Report of Foreign Bank and Financial Accounts (FBAR). By no later than May 13, 2016, this interim guidance...more

Financial Services Quarterly Report - Second Quarter 2015: Is the Long Wait Worth it? European Long-Term Investment Funds (ELTIFs)...

The long-awaited European regulation on European long-term investment funds (ELTIF Regulation) was finally published in the Official Journal of the EU on May 19, 2015. The ELTIF Regulation will offer fund managers a new label...more

Negative Interest Rate Consequences

Over the last few months, the financial press has been filled with reports of negative interest rates. For example, on December 18 2014, the Swiss National Bank announced that it would move from a zero percent interest rate...more

News from Second and State

Week two of the budget stalemate is behind us, and there’s very little news to report. While news of a potential stop-gap budget and possible agreement on the imposition of a natural gas extraction tax might seem encouraging,...more

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