El 7/24/24, FinCEN actualizó su página de preguntas frecuentes sobre BOI (“Beneficial Ownership Information”) para incluir una pregunta nueva y una nueva actualización. FinCEN afirma que seguirá brindando orientación sobre...more
On 7/24/24, FinCEN updated its BOI FAQs page to include one new question and one new update. FinCEN states that it will continue to provide guidance on how to submit beneficial ownership information; including updating the...more
Plan sponsors of Code Section 403(b) tax-sheltered annuity plans (“403(b) plans”) that have not already done so may want to consider applying for an IRS determination letter or planning and budgeting for the process next year...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 24, 2024, issued two new FAQs providing guidance on 1) how to obtain a taxpayer identification number (TIN) in a manner to ensure...more
In a new round of FAQ, FinCEN shed light on how entities that are disregarded from their owners for Federal income tax purposes should handle tax identification numbers (TINs) under the Corporate Transparency Act (CTA)....more
The Corporate Transparency Act (the CTA) went into effect earlier this year, although many uncertainties about the CTA's application still remain. To help remedy those uncertainties, the Financial Crimes Enforcement Network...more
Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more
Reporting requirements under the Corporate Transparency Act (CTA) will go into effect beginning January 1, 2024. Under the CTA, many business entities formed or registered in the US will be required to provide the personal...more
Effective January 1, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) will require certain newly formed and pre-existing entities to submit information regarding their beneficial owners...more
After significant delay, the day is finally here! The 2022 EEO-1 Component 1 data collection opened today, Tuesday, October 31, 2023. The EEOC urges filing employers to begin the filing process as soon as possible to meet...more
This is the second in a two-part series discussing the Corporate Transparency Act (CTA) – new legislation enacted by Congress in January 2021, as part of the Anti-Money Laundering Act of 2020. Read the first part of this...more
Founders and operators, is your company prepared to report its Beneficial Ownership Information (BOI)? Unless an exemption applies, you may be required under the Corporate Transparency Act (CTA) to identify and report the...more
Background - The Corporate Transparency Act (CTA) was enacted by the United States Congress, and signed into law by President Joseph Biden, in 2021 as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA...more
Physician recapitalization transactions are complex by nature and often present myriad issues. At Foley, in our representation of both investors in, and sellers of, physician practices, we note how often tax issues become...more
A federal law adopted in 2021 takes effect on January 1, 2024, and imposes reporting obligations on many entities that may not be accustomed to reporting much information. This article provides a brief overview of the law,...more
On October 21st, the IRS announced changes to its qualified plan determination letter program. Most notably, the program has been expanded to include section 403(b) tax-sheltered annuity plans (“403(b) plans”). Although...more
In Revenue Procedure 2022-40, the IRS recently expanded the determination letter program to allow applications by individually-designed 403(b) plans. This expansion will allow 403(b) plan sponsors to request a determination...more
The IRS has had a determination letter process for qualified plans under Code section 401(a), like 401(k) and other defined contribution plans, for many years. A favorable IRS determination letter would give the sponsoring...more
The IRS has issued guidance that for the first time permits companies to apply for determination letters for individually-designed 403(b) Plans. Under the new guidance, determination letters will be available for 403(b) plans...more
On Sept. 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) released the final rulemaking regarding the Beneficial Ownership Information (“BOI”) and Reporting Requirements of the Corporate Transparency Act (“CTA”)...more
On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued the highly anticipated final rule, Beneficial Ownership Information Reporting Requirements (the “Final Rule”), implementing the beneficial...more
AML (Anti Money Laundering) reforms led to the Corporate Transparency Act. On January 1, 2021, Congress enacted the National Defense Authorization Act for Fiscal Year 2021 (the NDAA), after overriding a presidential veto....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 25, 2021 – October 29, 2021... October 25, 2021: The IRS released a memorandum...more
Critical in Cases of Identity Theft or Fraud A news release issued by the Internal Revenue Service (IRS) on July 30, 2021, reminds holders of Employer Identification Numbers (EINs) that a change in responsible party requires...more