Aggregation Rules

News & Analysis as of

MoFo New York Tax Insights - Volume 6, Issue 11

Resident Is Not Subject to Use Tax on Yacht Briefly Docked in the State - In Matter of Michael Pellino, DTA No. 825869 (N.Y.S. Div. of Tax App., Oct. 1, 2015), a New York State Administrative Law Judge concluded that...more

At Long Last – Allocation and Accounting Rules

Good things come to those who wait. The tax-exempt bond industry has waited 18 years for a missing reserved section of the private activity bond regulations, the allocation and accounting regulations, Treas. Reg. Section...more

Following the Wisdom of the Crowd? A Look at the SEC’s Final Crowdfunding Rules

In this alert, we provide a detailed overview of the final rules, Regulation Crowdfunding, which will be applicable to crowdfunding offerings conducted in reliance on Section 4(a)(6) of the Securities Act of 1933 as amended...more

CFTC Updates Position Limits Rule

On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the...more

CFTC Proposes Revisions to Pending Aggregation Rules

The Commodity Futures Trading Commission (CFTC) has voted to seek public comment on revisions to its proposed rules requiring the aggregation of certain accounts for purposes of the CFTC's speculative position limits. If...more

CFTC Modifies Position Limit Aggregation Proposal

The Commodity Futures Trading Commission has modified its position aggregation proposal, which initially was proposed on November 15, 2013. Under the 2013 proposal, an entity owning 50 percent or more of another entity would...more

CFTC Proposes Supplement to Aggregation Proposed Rules for Position Limits

On September 22, 2015, the Commodity Futures Trading Commission (“CFTC”) issued for public comment a supplement (the “Supplemental Aggregation Proposal”) to its proposed aggregation rules for position limits for related...more

CFTC Proposes Amendments to Position Limit Aggregation Exemption Rules

On September 22, 2015, the Commodity Futures Trading Commission (CFTC) proposed certain changes in a supplemental notice of proposed rulemaking (the “Supplemental Notice”) to the position limit aggregation rules and...more

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

BEA’s BE-180 Benchmark Survey of Financial Services Providers: Implications for U.S. Asset Managers

In the fall of 2015, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) will administer its next Benchmark Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign...more

While New Methane Rules Get Most of the Attention, EPA Also Proposes New Site Aggregation Policies for the Oil and Gas Sector and...

On August 18, 2015, the U.S. Environmental Protection Agency ("EPA") released and asked for comments on a number of proposed rules affecting the oil and gas industry. While the methane emission regulations have received the...more

OFAC Issues Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued revised guidance with respect to entities owned 50 percent or more in the aggregate by one or more blocked persons....more

SANCTIONS UPDATE - New Treasury Guidance on Aggregation of Ownership Interests

On August 13, the U.S. Department of the Treasury published revised guidance on the treatment of entities owned by persons whose property and interests in property are blocked under the Executive Orders and regulations...more

OFAC Issues Revised Guidance on Aggregation of Ownership Interests

On August 13, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued revised guidance with respect to the “50% Rule,” which established that an entity owned 50% or more, directly or indirectly, by a...more

CFTC FORM 40/40S Reporting Requirements

Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity Futures Trading Commission (CFTC) has seemingly increased the number of Form 40/40S requests it...more

DC Circuit Strikes Down EPA “Aggregation” Policy for Regions Outside the Sixth Circuit

On May 30, 2014, the U.S. Court of Appeals for the District of Columbia Circuit nullified an EPA Directive that attempted to reassert its “functional interrelationship” standard for aggregating air pollution sources. This EPA...more

"Developments Regarding Aggregate Contribution Limits"

In the aftermath of the U.S. Supreme Court's decision in McCutcheon v. FEC, striking down the aggregate limits imposed on individual contributions under federal law, several jurisdictions also have taken steps to address...more

CFTC Staff to Host Position Limits and Aggregation Roundtable

Market participants are encouraged to submit further comments to the Commission. The Commodity Futures Trading Commission (CFTC) on May 27, 2014 announced that it will hold a public roundtable at the CFTC on Thursday,...more

The Devil is in the Details: Advising Your Clients on the Affordable Care Act

The Affordable Care Act (ACA) represents a fundamental shift in healthcare delivery and insurance. The law is complex and many of its provisions are delayed due to implementation difficulties. However, virtually all...more

New IRA Rollover Interpretation Has Implications For Banks

In a new interpretation with implications for banks, the Internal Revenue Service (IRS) announced its intent to change course and limit rollovers from an Individual Retirement Account (IRA) to one rollover per year per...more

In wake of McCutcheon case, states abandon aggregate contribution limits

Early this month, the United States Supreme Court invalidated federal aggregate limits on individual political contributions in the case McCutcheon et al. v. Federal Election Commission.... ...In McCutcheon, the Court...more

Supreme Court Opens New Political Contribution Opportunities for Big Donors

In a divided 5-4 ruling in McCutcheon v. Federal Election Commission, the Supreme Court today struck down the federal election law’s long-standing “biennial limit” – the aggregate amount that a person can give to federal...more

U.S. Supreme Court Strikes Down Aggregate Contribution Limits

On Tuesday morning, a divided United States Supreme Court issued its opinion in the case of McCutcheon v. Federal Election Commission (572 U.S. ____ (2014)), striking down a portion of federal campaign finance law that...more

McCutcheon Could Jeopardize NJ Pay-To-Play Restriction; Laurence Laufer and Rebecca Moll Freed Comment for Law 360

The U.S. Supreme Court’s decision in McCutcheon vs FEC striking down aggregate limits on donations to political parties and candidates casts doubt on the constitutionality of similar caps under local pay-to-play ordinances in...more

Supreme Court strikes down individual aggregate contribution limits

The United States Supreme Court has struck down a long-standing campaign finance provision that limited the total amount that individuals may contribute to federal political candidates and committees. The decision, in the...more

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