BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Correcting Problems With Your Retirement Plan
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
Did the IRS Just Help or Hurt the Bitcoin Economy?
Tax Traps of Employment Documents
BB&K's Isabel Safie Discusses the Implications of IRS’ Definition of Governmental Plan Status
Fantasy Football: The Legal Reality
Hot Topics for Waste-to-Energy Investors and Developers
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more
A representative from the Internal Revenue Service (IRS) recently signaled that new rules are expected to be released that could significantly impact taxpayers' ability to claim discounts on gifts of interests in...more
This Week: CMS Releases Guidance on Fast Track Process for 1115 Waivers for Medicaid and CHIP... Healthcare.gov CEO Sends Letter to State Insurance Commissioners Concerning 2016 Premium Decisions... Medicare Board of Trustees...more
Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more
The IRS has announced significant changes to its qualified plan determination letter program. These changes, which become effective January 1, 2017, impact individually-designed plans.
Favorable determination letters...more
The Internal Revenue Service ("IRS") announced, on July 21, 2015, a major curtailment of its determination letter program for individually designed qualified retirement plans ("Individually Designed Plans") that will impose...more
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
The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more
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
The misclassification of employees as independent contractors continues to be a hot issue and to receive attention at the state and federal levels. Last week, the U.S. Department of Labor, Wage and Hour Division (“DOL”)...more
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
The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies.
In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more
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
The Department of Labor’s Wage and Hour Division has issued an “Administrator’s Interpretation” that elucidates the DOL’s views on the issue of who is an employee and who is an independent contractor under the Fair Labor...more
Two recent legislative developments, which have largely gone unnoticed, will dramatically raise the stakes for mortgage servicers and originators who file IRS Forms 1098. First, the Trade Preferences Extension Act of 2015,...more
The IRS issued the much anticipated proposed regulations that severely curtail the practice of a fund manager waiving management fees in exchange for a share of future partnership profits. In essence the regulations tighten...more
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
On June 29, 2015, President Barack Obama signed the Trade Preferences Extension Act (the Act) into law. In addition to containing several revenue offsets, the Act significantly increased penalties for incorrect information...more
In this Update Series, we provide continuing updates on the key developments relating to multiemployer pension plans, as well as practical considerations for the companies that participate in them. These union benefit funds...more
The Internal Revenue Service (IRS) has announced that, effective January 1, 2017, the existing procedure for issuance of favorable IRS determination letters for qualified pension, profit-sharing and 401(k) plans will be...more
As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more
Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income.
On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more
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
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 Internal Revenue Code has provided an incentive under Section 170(h) for charitable conservation gifts. Since at least 2002 there has been an interest in combining through partnership those land owners who may have little...more
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