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Tax Finance & Banking

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

IRS Issues New Rules for Management Contracts involving Tax-Exempt Financed Facilities

by Miller Canfield on

The Internal Revenue Service (IRS) issued Revenue Procedure 2017-13 (Rev. Proc. 2017-13) on Jan. 17, 2017. The procedure provides more flexible, modern rules for structuring management contracts involving tax-exempt financed...more

FY2018 Massachusetts Budget Update: The Senate Ways and Means Budget

On May 16, 2017, the Massachusetts Senate Ways and Means Committee proposed a $40.791 billion FY2018 budget. The budget, which increases spending by 3.3% over FY2017 levels, spends $280 million more than Governor Charlie...more

Outline for Discussion of New Issue Price Rules

New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon. This outline describes the new issue price rules, provides a high-level strategic analysis to help guide a...more

Podcast - Shrink the Section 457A Tax on Hedge Fund Management and Incentive Fees and Expand Your Impact

by Ropes & Gray LLP on

In a recently released Ropes & Gray podcast, asset management partner Isabel Dische, tax partner Brett Robbins, and private client partner Cameron Casey discuss the effect of Section 457A on pre-2009 management and incentive...more

Families Can Use a Tax-Advantaged ABLE Account to Save for Disability Expenses

by Bowditch & Dewey on

Governor Charlie Baker recently announced the launch of a state sponsored Achieving a Better Life Experience (ABLE) account program that has been long awaited by disabled individuals and their families. This program serves as...more

Forgiveness of Debt Can Prove Unforgiving, But a New Federal Court Decision Gives Cause for Optimism

by Hinshaw & Culbertson LLP on

A federal court in New Jersey recently dismissed a putative class action filed under the Fair Debt Collection Practices Act, which had argued that it was deceptive conduct for a debt collector to inform the debtor that...more

The Time is Right to Contact Recordkeepers About Hardship Substantiation

If your 401(k) plan recordkeeper has not talked to your company lately about hardship distributions, it may be time to reach out to the recordkeeper. The short story is that the IRS recently issued an internal memorandum...more

Guidelines for Making Prudent Investment Decisions

by Moskowitz LLP on

When the creator of a trust is living, they can manage their trust and invest it however they wish. When a named trustee assumes control of a trust, however, they have a number of investment obligations and duties. A...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

Simple Advice to Retirement Plan Sponsors

by Ary Rosenbaum on

I don’t know about you, most of the advice I got growing up was usually wrong. Maybe some very unsuccessful people surrounded me when I was younger, but advice can be biased and self-serving at times. The best advice I would...more

Challenge and Counter-Proposal

by Moskowitz LLP on

In Part I, we outlined the scope of the November 2016 summons served on Coinbase to identify its users and their transaction activity and the IRS’ justification for requesting this data under 26 U.S. Code § 7602. Section 7602...more

The Final Countdown: New Issue Price Regulations Effective June 7th

by Bracewell LLP on

The June 7th effective date for the final Treasury Regulations relating to the establishment of “issue price” of tax-exempt obligations (the “New Regulations”) is drawing near. In fact, for obligations that are scheduled to...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

The Summons

by Moskowitz LLP on

Coinbase is a San Francisco-based cryptocurrency exchange company that operates bitcoin and other digital asset transactions and storage for over one million users in 190 countries....more

Cities Can Sue Banks for Predatory Lending, U.S. Supreme Court Says

by Best Best & Krieger LLP on

While the nationwide economy has steadily improved since the recession, many cities are still clawing their way back to financial stability. California, in particular, was hit hard by the foreclosure crisis, leaving cities in...more

Tax Round Up - May 2017

by Proskauer Rose LLP on

Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Succession Planning—Bet the Farm on It

by Ward and Smith, P.A. on

Despite recent trends toward consolidation in the agricultural industry, farming generally remains a family affair. According to the United States Department of Agriculture, 97 percent of all farms in the United States are...more

Forfeiture Case Based on Alleged Elaborate $230 Million Russian Laundering and Fraud Scheme to Settle

by Ballard Spahr LLP on

On the eve of trial this past Friday, the government announced an agreement to settle, subject to court approval, a major civil forfeiture action in the Southern District of New York. In the case, United States v. Prevezon...more

Advisors Advantage - May 2017

by Ary Rosenbaum on

For Retirement Plan Providers, It's All About Relationships. That is what it's about. The retirement plan business is a relationship driven business. It's about connecting with other plan providers and more...more

Lending Industry Take Note: U.S. Supreme Court Rules on Scope of Right to Sue Under Federal Fair Housing Act

by Partridge Snow & Hahn LLP on

A city’s lawsuit against various banks under the federal Fair Housing Act (“FHA”) to recover property tax revenues allegedly lost due to discriminatory lending practices has survived . . . for now. In a recent decision, the...more

New Cash Balance Retirement Plan Guidance

by Dickinson Wright on

On April 7, 2017, the IRS issued a memorandum relating to cash balance retirement plans. A cash balance plan is a defined benefit pension plan which looks like a defined contribution plan because participants have individual...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

Small 401(k) Plans Have Bigger Problems Than Larger Plans

by Ary Rosenbaum on

Common sense would make you think that larger 401(k) plans would have the larger problems. Sometimes common sense and reality are mutually exclusive. Thanks to the quirks of the retirement plan business and how it prices...more

Corporate Criminal Offence: Failure to Prevent Facilitation of Tax Evasion

The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement...more

Recent Amendments to the Alberta Investor Tax Credit Program

by Dentons on

The Government of Alberta recently passed Order in Council 135/2017 (the Recent Amendments) which amends the Alberta Investor Tax Credits Regulation (the Regulations) and makes the Alberta Investor Tax Credit (AITC) program...more

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