U.S. Treasury

News & Analysis as of

Colleges/Universities Granted Extended Relief for Premium Reductions in Connection with Student Health Insurance

The Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) on Friday extended enforcement relief, via publication of FAQs About Affordable Care Act Implementation Part 33 (“FAQs”),...more

Student Health Insurance Plans and the ACA: Agencies Provide Enforcement Relief that Allows Colleges and Universities to Continue...

Late last week, the Departments of Labor (“DOL”), Health and Human Services (“HHS”) and the Treasury (collectively, the “Agencies”) issued a very welcome FAQ that will allow higher education institutions to continue...more

Application of New Debt-Equity Regulations to Securitizations

On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more

Temporary Relief for Certain Student Health Plans Extended Indefinitely

In recently issued guidance, the U.S. Departments of Treasury, Labor, and Health and Human Services indicated that they will indefinitely extend relief to colleges and universities that subsidize the cost of individual...more

Recently Issued Final, Temporary and Proposed Treasury Regulations Regarding the Allocation of Partnership Liabilities and...

On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Proposed Regs May Limit US Estate Plan

On August 2, 2016, the US Treasury issued long-awaited pro- posed regulations under Code section 2704 that make comprehensive and very significant changes to the valuation of interests in many family-controlled entities for...more

Alert: New US Debt-Equity Rules Target Earnings Stripping

On October 13, 2016, the IRS and the Treasury Department issued new rules largely designed to prevent highly related corporate taxpayers from claiming the tax benefits of “earnings stripping,” or the payment of excessive...more

Treasury Targets Tax Deferral in Leveraged Partnership Structures with New Regulations

The Treasury issued new final, temporary and proposed regulations that take aim at, and significantly reduce the effectiveness of, leveraged partnership structures intended to achieve tax deferral to the contributing partner....more

Final and Temporary Debt-Equity Regulations Under Section 385 Implement Highly Favorable Changes

On Oct. 13, 2016, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final and temporary regulations under Section 385 governing the treatment of certain instruments as debt or equity...more

The U.S. Department of the Treasury, Office of Foreign Assets Control Ends Its ‘Burma Sanctions Program’

On 7 October 2016, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) ended all economic and financial sanctions with respect to Myanmar (referred to by OFAC as Burma). The move had been...more

Treasury Issues Final & Temporary Section 385 Regulations

On October 13, the Treasury released highly anticipated final and temporary regulations (T.D. 9790) under Section 385, which authorizes the Treasury to devise regulations to determine when an interest in a corporation is...more

There is life after death...of the Bottom-Dollar Guarantee

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

Treasury Makes it Easier for Pension Plans to Pay Partial Annuities

The Department of Treasury has issued final regulations that simplify the rules that allow retiring participants to simultaneously elect a partial lump sum and a partial annuity from a defined benefit pension plan. Under the...more

Now You Can Have Your Cake and Eat It Too: New Pension Distribution Rules Allow More Flexibility

If you are one of the lucky few employees who participate in an employer’s defined benefit retirement plan, you previously had to choose between receiving your benefits in a lump sum or in annuity payments. However, in the...more

Your Daily Dose of Financial News

Like a hot new underground nightclub [I presume.  Not exactly  my scene], Marcus—Goldman Sachs’ new online lending platform aimed at the consumer banking segment—requires a password. Goldman’s reportedly sending out the...more

Trade & Manufacturing - News of Note - October 2016

The WTO Opens Its Doors for the 15th Annual Public Forum - For the fifteenth time, the World Trade Organization (WTO) hosted its annual Public Forum in Geneva to provide a platform for an exchange of views among...more

The MPRA: One Size Fits No One

This is another in our series addressing the continuing deterioration of multi-employer defined benefit pension plans. Regardless of the identity of the next tenant of the White House, a major item on the new...more

New Partnership Liability and Disguised Sale Regulations

Key Points - - Final, temporary and proposed regulations issued on October 5, 2016, address complex rules dealing with partnership disguised sales and debt allocation rules under Sections 707 and 752 of the Internal...more

Final IRS Regulations Simplify Pension Plan Requirements for Partial Annuity Distributions

The Department of Treasury and Internal Revenue Service issued final regulations addressing the minimum present value requirements for pension benefits payable partly as an annuity and partly in an accelerated form, usually a...more

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

OFAC Guidance on U.S. Dollar Transactions Involving Iran

On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more

Federal Tax Guidance Regarding RICs’ Investments in Commodities, Certain PFICs, and “Securities”

The Treasury Department (Treasury) and the Internal Revenue Service (Service) recently issued proposed regulations that, if finalized as proposed, could have a significantly adverse effect on the ability of a regulated...more

Reversing Course—Proposed Regulations Reverse IRS Ruling Position on Treatment of Income from CFCs and PFICs for RIC Qualification...

On September 27, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (REG-123600-16) (the Proposed Regulations) under section 851 addressing the income test applicable...more

Money, bits and banking: Florida case implicates legal status of digital currencies in the US

Introductory level economics textbooks often begin with a discussion of a surprisingly tricky question – what is money? In economics parlance, money is not simply what is in your wallet; rather, it is any asset that functions...more

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