Tax Finance & Banking

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IRS to Begin New Procedure for Initiating Tax-Exempt Bond Audits

In late 2016, the IRS Tax-Exempt and Government Entities Division (“TE/GE”) released a memorandum to its examiners outlining a new procedure for initiating audits of tax-exempt bonds. The Commissioner of TE/GE recently noted...more

New Regulations on Issue Price of Tax-Exempt Bonds

On December 9, 2016, the Department of the Treasury and Internal Revenue Service (IRS) published final regulations on the definition of “issue price,” for purposes of the arbitrage rules that apply to tax-exempt bonds....more

Getting Into Compliance with Your Foreign Account Reporting, Part II

In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP)....more

The Small Stuff That Plan Sponsors Should Sweat Out

It’s often said that you shouldn’t sweat the small stuff. The problem is that many times, a retirement plan sponsor ignores the small stuff, and that small stuff leads to bigger problems. This article is about small details...more

IRS Sets Deadline for Retroactive Fixes to 403(b) Retirement Plan Documents

In January 2017, the IRS published Revenue Procedure 2017-18 which set March 31, 2020 as the last day to take advantage of the remedial amendment period under Revenue Procedure 2013-22 to retroactively fix defects in 403(b)...more

Getting Into Compliance with Your Foreign Account Reporting, Part I

With the 2015 release of the “Panama Papers,” roughly 11.5 million documents detailing personal financial information of wealthy individuals and identifying nearly 215,000 offshore entities are now available to government...more

Friends and Family and Criminal Forfeiture

One of the many potential consequences of a criminal conviction is that the government may seize assets held by the defendant’s family to satisfy a criminal forfeiture order against the defendant himself. In United States v....more

Reporting Foreign Income: Four Common Misconceptions

The U.S. government has stringent reporting requirements when it comes to foreign assets and income, but many people are still not coming into compliance based on some mistaken beliefs. Here are four common misconceptions...more

Next off the block - AEOI

You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it's not over yet! Next off the block is the Automatic Exchange of Financial Account...more

Your Daily Dose of Financial News

The struggle to attract and retain businesses and the jobs they provide has increasingly led to states and cities squaring off against others, with competing tax incentive packages the very real currency of the battle....more

Warning Signs that Your Retirement Plan Might Be In Trouble

When it comes to your health, there are warning signs when you’re about to suffer a heart attack or a stroke. If you pay attention to these warnings signs, you might avoid a serious medical emergency. While a retirement plan...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Update: Upheaval in the German Restructuring Market: Need-to-Know Facts, Alternative Tools and New Draft Law

To date, a debt waiver has been frequently used as a tool to successfully restructure German-based companies in financial difficulties. A decision of the German Federal Fiscal Court (Bundesfinanzhof) published on...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue...

If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number (EIN) and maintain adequate books and records to...more

Tax Lien Foreclosure – Rights of Mortgage Holders and Unassessed Owners

Experienced tax collectors and treasurers know that mortgage holders and unassessed owners of record have the right to receive copies of certain notices during the tax lien foreclosure process. But what are these entities’...more

401(k) Plan Sponsors: Don’t Make These Mistakes

Larry David is one of my favorite people because he created two of the greatest shows in television history: “Seinfeld” and “Curb Your Enthusiasm.” The shows are similar in that they depict bad ideas or bad behaviors. Curb...more

Your Daily Dose of Financial News

There’s been a bit of a stir in the paint world, with Dutch firm Akzo Nobel rejecting a takeover bid from PPG Industries valued at $22 billion. In a statement, Akzo claimed that the offer “substantially undervalues” the...more

The New Tax Landscape for Investment Management

Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Funds Services Practice Group hosts a series of candid, interactive discussions on what is going on now in the investment management world,...more

The New Tax Landscape for Investment Management [Audio]

Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Funds Services Practice Group hosts a series of candid, interactive discussions on what is going on now in the investment management world,...more

Auf Wiedersehen to the tax privilege on restructuring gains – a blow to the German restructuring tool kit

A recent judgment of the German Federal Fiscal Court (FFC) will have significant impact on the restructuring tool kit afforded under German law. The FFC has found that the existing practice of permitting a tax liability...more

IRS Issues a Memorandum on Substantiation Guidelines for Safe-Harbor Hardship Withdrawals from 401(k) Plans

On February 23, 2017, the Internal Revenue Service (“IRS”) issued a Memorandum to IRS agents. The Memorandum identified the steps agents should take, in examining a 401(k) plan, to confirm that a hardship withdrawal is...more

HB 2946 – The New and Improved Illinois Angel Investment Tax Credit Program

For those who don’t know, Illinois has had an “Angel Investment” program since 2012 where investors who invested in qualifying companies would receive a 25% tax credit against their Illinois income taxes. Sounds great in...more

Did Hardship Distributions Just Get Easier?

In a previous blog, we addressed an issue of Employee Plans News in which the IRS took the position that 401(k) plan administrators must maintain hardship distribution records and should not rely on electronic participant...more

2016 Foreign Bank Account Reports: New Filing Deadline

The U.S. government continues to pursue aggressively individuals and businesses for the failure to report foreign accounts and other non-U.S. assets. In particular, and with limited exceptions, all U.S. individuals and...more

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