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Health and Human Services, Labor and Treasury Departments Release New Summary of Benefits and Coverage Templates and Accompanying...

The Departments of Health and Human Services (“HHS”), Labor (“DOL”), and Treasury (the “Departments”) have jointly released final changes to the Summary of Benefits and Coverage (“SBC”) template, the Uniform Glossary, and...more

International Crackdown: Tax Authorities Look to Employment Structures in Initiating Audits

In structuring their workforces abroad, taxes are a major driving force for employers—and if recent government initiatives are any indicator, employers should take care when considering the tax implications of their staffing...more

FinCEN Deputy Director: Industry Collaboration Key to Finalizing Customer Due Diligence Rule

On May 16, FinCEN Deputy Director Jamal El-Hindi delivered remarks at the Institute of International Bankers (IIB) Annual Anti-Money Laundering Seminar in New York. The focal point of El-Hindi’s remarks was recent Treasury...more

FinCEN Issues New Beneficial Ownership Regulations

Under the dark cover of the Panama Papers scandal, FinCEN moved quickly to issue its beneficial; ownership regulations. For all of the US regulatory and financial industry bluster, it is about time. The United States stands...more

IRS Offers Tax Guidance Relating to Money Market Fund Rules

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

Four Things You Need to Know About the Mauritius-India Protocol

International investors have frequently used Mauritius holding companies for their Indian investments, seeking to take advantage of the exemption under the India-Mauritius income tax treaty (the “Mauritius Treaty”) from...more

Law And Accounting Committee Summary Of Current FASB Developments

In March, 2016, the FASB issued Accounting Standards Update No. 2016-09, Compensation - Stock Compensation (Topic 718), Improvements to Employee Share-Based Payment Account. This update simplifies accounting for share-based...more

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

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...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

Might You Be Stumbling Into Being Subject to the U.S. Department of Labor’s Conflict of Interest Regulatory World?

The U. S. Department of Labor’s Conflict of Interest regulatory package (the “COI Rules”) reaches far more than traditional trustees named in retirement plan documents. Many financial advisors, tax advisors, investment...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

Good News on “Bad Boy” Guarantees – IRS Reverts to Prior Position in Recent Legal Advice Memorandum

On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the...more

The Legacy of Michigan Senator Levin and Offshore Taxation Issues

When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to...more

IRS Notice Offers Relief to Issuers of Variable Insurance Products in Response to Pending Money Market Fund Reforms

On May 5, 2016, the IRS issued Notice 2016-32, 2016-21 I.R.B. 1, which affords relief with respect to the application of the diversification requirements of IRC § 817(h) to variable life insurance and annuity contracts...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

Your daily dose of financial news The Brief – 5.10.16

Big news out of the online lending space, as Lending Club’s chair and CEO—Renaud Laplanche—has resigned after an internal review “showed a violation of the company’s business practices” related to sales of $22 million in...more

Panama Papers: Prosecutors Launch Investigations

When a scandal hits the media like the Panama Papers leak of 11.5 million confidential legal records, we all know what to expect. Criminal investigations, regulatory responses, and of course, congressional hearings of some...more

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

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

New Collective Investment Vehicles

This week's Federal Budget ushered in a new era in investment management in Australia with the announcement that the Federal Government will introduce a new tax and regulatory framework for two new types of collective...more

2016-17 New York State Budget

On April 13, 2016, Governor Andrew M. Cuomo signed the 2016-17 New York State Budget into law. We summarize the highlights of the revenue provisions below. Personal Income/Estate Taxes Personal Income Tax rates are scheduled...more

Corporate E-Note - April 2016

In an article published by the Birmingham Business Journal in the April 1 print edition, India Vincent provides insights on a series of questions related to cybersecurity, including some best practices to help monitor for and...more

New Guidance on Bad Boy Guarantees

The IRS Office of Chief Counsel recently released a memorandum (#AM2016-001) addressing the proper tax treatment of nonrecourse carve-outs (or bad boy guarantees) in the partnership context. According to the memorandum, such...more

Taxpayer Entitled to Section 1033 Gain Exclusion Despite Holding Only a Beneficial Ownership Interest in Condemned Property

In PLR 201609003, the IRS determined that a taxpayer was entitled to exclude gain attributable to the forced transfer of the taxpayer’s ownership of public use facilities, even though the taxpayer did not hold legal title to...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

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