U.S. Treasury

News & Analysis as of

Hawai’i Receives Approval for the First State Innovation (Section 1332) Waiver

The federal Department of Health and Human Services and Department of Treasury (the Departments) agreed that certain small employer health insurance coverage provisions of the Affordable Care Act (ACA) would be waived for the...more

Client Alert: Issue Price Regulations

Final issue price regulations ("Final Regulations") were published in the Federal Register on December 9, 2016. The definition of "issue price" applies to bonds sold on or after June 7, 2017....more

New U.S. Sanctions Concerning Russia: President Obama Logs Out of 2016 with an Amendment to the U.S. Cyber-related Sanctions...

On December 29, 2016, OFAC (the U.S. Department of the Treasury, Office of Foreign Assets Control) imposed sanctions on five Russian entities and four Russian individuals in connection with their alleged efforts to interfere...more

New Temporary and Proposed Regulations Regarding Debt Allocations for Partnerships - 'Oh My' - Tax Update Volume 2017, Issue 1

Although There Are Aspects of the Regulations that Practitioners and Taxpayers Still Disagree With, There Are Others that Are an Improvement on What Was Proposed Earlier. From 2013 through 2014, the IRS and the U.S....more

President-Elect Trump Announces Nominations for Treasury Secretary and Commerce Secretary

Over the past month, President-elect Donald Trump has made several selections for key administration posts. Notably, President-elect Trump said he would nominate Steven Mnuchin to serve as Treasury Secretary. Mnuchin was the...more

"Privacy & Cybersecurity Update - December 2016"

In this month's edition of our Privacy & Cybersecurity Update, we examine modifications to New York state's proposed cybersecurity regulations for financial institutions, a 5th Circuit ruling that a phishing scam is not...more

Treasury and DOL Update 2016-2017 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 October 31, 2016, the U.S. Department of the Treasury and the Internal Revenue Service...more

Stock Dividend Foot Faults

Recently the Treasury issued proposed regulations for Section 305. The proposal was prompted by Section 6045B, enacted in 2008 and effective only under regulations requiring the issuer of stock to provide basis reporting. A...more

Lawsuit filed to set aside IRS Notice 2016-66

Two months ago, without any prior warning or public notice, the IRS issued Notice 2016-66 which defined a number of common captive insurance transactions as “transactions of interest.” The Notice is limited to captive...more

Fintech Advocacy Group Reaches Out To Trump

A financial technology advocacy group has reached out to President-elect Donald J. Trump, encouraging him to create a new position at the Treasury Department to support fintech. The position that the President-elect and his...more

US Issues Additional Russian/Ukrainian Designations and New General License, EU Extends Sanctions Targeting Russia

On December 20, 2016, the US Department of Treasury's Office of Foreign Assets Control (OFAC) added 15 individuals and entities and two vessels to the List of Specially Designated Nationals and Blocked Persons (SDN List) and...more

Counselor to the US Treasury Secretary, Antonio Weiss, Argues for the Preservation of the FSOC

Antonio Weiss, Counselor to the US Treasury Secretary, argued that the FSOC has become a “critical nerve center during episodes of market volatility or stress,” providing a forum to assess system-wide risks, which was missing...more

U.S. Antiboycott Compliance: New Federal List Published

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more

Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities 

Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the...more

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

On December 2, 2016, the Treasury issued Notice 2016-73, describing future regulations that will modify the Killer B regulation issued in 2011; the modifications will stymie newly discovered variations of the Killer B...more

36-Month Rule for Reporting Discharges of Indebtedness Is Repealed

The Treasury Department has issued proposed amendments to the regulations governing the reporting of discharges of indebtedness that will impact the filing of Forms 1099-C by member banks for the 2016 calendar year. In...more

Treasury/IRS Provide Early Holiday Present: Final “Issue Price” Regulations Released

After two sets of proposed regulations, Treasury and IRS have now released final regulations on the definition of “issue price” for purposes of arbitrage investment restrictions that apply to tax-advantaged bonds (the “Final...more

Final Treasury Regulations Defining Issue Price

For a variety of reasons related to arbitrage, it often is important to identify the "issue price" of tax-exempt bonds with precision and certainty. Existing Treasury Regulations generally allow the "issue price" of publicly...more

Final Issue Price Regulations Significantly Change Current Rules

On December 9, 2016, the IRS released final Treasury Regulations (the “Final Regulations”) relating to the “issue price” of tax-exempt bonds for purposes of arbitrage investment restrictions. Although, on balance, an...more

Update On Proposed Tax Regulations Affecting Availability of Valuation Discounts to Family Business Owners

In September, we posted a blog discussing the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704 proposed regulations) that could...more

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

Regulators Implement Enhanced Oversight and Propose Transparency for the Treasury Market

On October 24, 2016, the Federal Reserve Bank of New York (FRBNY) held a conference on “The Evolving Structure of the US Treasury Market” (Conference). The Conference was a sequel to the first annual such event where...more

CDFI Fund Announces $7 Billion Allocation of New Markets Tax Credits

In Depth - On November 17, 2016, the US Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) announced the largest single round award of New Market Tax Credit (NMTC) allocations...more

West Coast Real Estate Update: November 2016 #3

Owners, Developers Face Challenges Converting Parking to E-Commerce Delivery Space - Because millennials make up an increasing number of urban residents, owners and developers of apartment and condominium buildings are...more

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more

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