U.S. Treasury

News & Analysis as of

Raising the Stakes for AML Compliance Officers: Court Refuses to Rule Out Potential Liability for Role in Employer's BSA...

Why it matters - A federal court judge in Minnesota has rejected the motion of a former chief compliance officer to dismiss the U.S. government's claim that he is liable under the federal Bank Secrecy Act for his...more

Integrated Health Reimbursement Accounts, Coordination with Family Coverage, and Notice 2015-87—Something’s Missing

Issued at the end of last year, Notice 2015-87 provided detailed guidance on a host of topics. The notice has been referred to colloquially in some quarters as the “pot luck” notice. Among other things, the notice, in Q&A 4,...more

Could 2016 Be the Year When Congress Finally Addresses Tax Reform?

Like Vladimir and Estragon waiting for Godot, Washington has been waiting for Congress to tackle tax reform. The reason for the lack of action is a fundamental disagreement between Democrats and Republicans over what reform...more

US Treasury and Commerce Departments Announce New Changes to Cuba Regulations

On January 25, 2016, the US Treasury Department’s Office of Foreign Assets Control (OFAC) and the US Commerce Department's Bureau of Industry and Security (BIS) announced new changes to existing US sanctions on Cuba,...more

FINRA Issues Notice on the Application of the Mark-Up Rule to Exempted Government Securities Transactions

The Financial Industry Regulatory Authority released Regulatory Notice 16-03, which discusses the Securities and Exchange Commission’s approval of amendments to FINRA Rule 0150 (Application of Rules to Exempted Securities...more

U.S. Treasury Department Eases Sanctions Under Iran Nuclear Deal

Changes Authorize Certain Transactions by Foreign-Incorporated Companies - On January 16, 2016, the U.S. Treasury Department eased economic sanctions on Iran and issued new licenses authorizing three new categories of...more

FinTech White Paper: Treasury’s Marketplace Lending RFI

Reed Smith has issued the first comprehensive white paper discussing the comments submitted in response to Treasury’s July 2015 Request for Information (RFI) on marketplace lending. The RFI, entitled “Public Input on...more

Update: IRS Withdraws Proposed Regulations on Substantiation of Donations in Response to Taxpayer Comments

Back in September of 2015, the Treasury and IRS issued proposed regulations related to section 170(f)(8)(D) providing an alternate framework for substantiating charitable donations. The proposal would require a donee...more

DOL and Treasury Update 2015-2016 Regulatory Agendas for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. On November 19, 2015, the U.S. Department of Labor (DOL) updated its Semi-Annual...more

An Ounce of Prevention…Is Tax-Free: IRS Expands Tax Relief to Pre-Data Breach Identity Theft Protection Services

As reported here after last year’s customer data security breaches at major U.S. corporations, the IRS announced special tax relief for identity protection services provided to individuals affected by a security breach. In...more

TTB Publishes Projected Regulatory Agenda as Part of Government’s Unified Agenda

As it does twice per year, the Alcohol and Tobacco Tax and Trade Bureau (TTB) recently published its projected Regulatory Agenda as part of the federal government’s “Unified Agenda.” Links to the U.S. Department of...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 23 of 24): Notice 2016-4 Postpones Reporting and...

Under the Affordable Care Act’s reporting requirements that have been the subject of this series, statements to responsible individuals (a/k/a “employees”)—i.e., Forms 1095-B and 1095-C—must be furnished on or before January...more

Manatt on Health Reform: Weekly Highlights - December 2015 #3

Guidance from HHS and Treasury sets a high bar for 1332 waiver approvals; Kentuckians support Medicaid expansion and their State Marketplace despite plans to change course; and South Dakota's executive budget includes funds...more

HHS, Treasury Issue Guidance on ACA State Innovation Waivers

The Departments of Health and Human Services (HHS) and Treasury have issued joint guidance on Affordable Care Act (ACA) “Section 1332” waivers, through which states can apply to implement alternative mechanisms to provide...more

Renewable Energy Update - Decemeber 2015 #2

Renewable Energy Focus - Representatives introduce Clean Energy Victory Bonds Act of 2015 - North American Windpower - - Dec 4 U.S. Representatives Zoe Lofgren, D-Calif., and Doris Matsui, D-Calif., have...more

Personal Planning Strategies - December 2015

2016 Estate, Gift and GST Tax Update - What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following...more

Wealth Management Update - December 2015

December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more

IREG Update - December 2015

US to negotiate insurance and reinsurance "covered agreement" with EU - The US Treasury Department and US Trade Representative (USTR) recently announced controversial plans to negotiate a “covered agreement” on insurance...more

Treasury Department and IRS Publish Final Hybrid Plan Regulations and Announce Extension of Required Amendment Date for Certain...

The Treasury Department and the IRS recently issued final regulations (the “2015 Final Regulations”) relating to hybrid retirement plans, including cash balance pension plans. The 2015 Final Regulations provide...more

Proposed Treasury Regulations Address Private Equity Management Fee Waivers and Profits Interests

The Internal Revenue Service ("IRS") and Treasury Department recently released proposed regulations under section 707(a)(2)(A) of the Internal Revenue Code of 1986 (the "Code) addressing the issuance of certain interests in...more

Treasury and U.S. Trade Representative Notify Congress of Intent to Initiate Negotiations on Covered Agreement With EU Regarding...

On Friday, November 20, 2015, the U.S. Department of the Treasury and the U.S. Trade Representative (USTR) notified the chairs of the U.S. House Financial Services Committee, House Ways and Means Committee, Senate Banking...more

Treasury and IRS Issue Additional Inversion Notice

The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by Treasury and the IRS on...more

ABLE Programs and Beneficiaries Boosted by Helpful Guidance from IRS and Social Security Administration

The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 (ABLE Act), one of the few recent examples of bipartisan cooperation on a new category of tax and budget expenditure, is both well-intentioned in its...more

Treasury Discusses Online Marketplace Lending

Why it matters - Regulatory oversight of online marketplace lending is moving forward, with representatives from the Department of the Treasury sharing six "central themes" drawn from comments on the agency's Request...more

IRS and Treasury Issue More Guidance on “Inversion” Transactions

The Treasury Department and the Internal Revenue Service have issued additional guidance about so-called “inversion” transactions. Generally, an inversion transaction results where a U.S. corporation (“U.S. Target”) is...more

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