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Tax Considerations and Pitfalls to Avoid for Fintech Startups

Creating a financial technology (fintech) firm comes with a host of tax considerations and implications. Decisions about the business’s structure, along with the location of both the business itself as well as its employees,...more

Inflation Reduction Act: Initial Takeaways for Green Technology, Taxes, and Healthcare

The Inflation Reduction Act of 2022, passed by the US Senate on August 7, 2022, will dramatically affect a range of climate change, healthcare, prescription drug pricing, and tax matters. With an investment of more than $400...more

Captive Insurance Opportunities and Solutions Post-COVID-19

Companies with coronavirus (COVID-19)-related losses and legacy liabilities may appreciate significant additional tax benefits from funding those legacy liabilities through a captive insurer before the end of this year. ...more

Final Section 956 Regulations Follow Approach of Proposed Regulations—with Two Helpful Modifications

Final regulations applicable to controlled foreign corporations and their US shareholders, issued by the US Treasury under Code Section 956, generally follow previously proposed regulations but introduce two modifications: a...more

California Supreme Court Shuts Down Consumer Sales Tax Suit

Dear Retail Clients and Friends: The California Supreme Court recently ruled that consumers cannot file suit to force a retailer to seek a refund of sales taxes from the California tax agency absent a determination by the...more

3/12/2019  /  CA Supreme Court , Retailers , Sales Tax

Proposed Regulations Would Modify the Application of Section 956 to Many Financing Transactions

The proposed modifications would create opportunities for enhanced CFC credit support. On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more

IRS, Treasury Issue Guidance on Section 965 Deemed Repatriation Rules, Signal Important Form 5471 Exception

Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders will be permitted to elect...more

M&A and Tax Reform—New Tax Considerations with Wide-Ranging Implications

New tax provisions have significant impact on structuring mergers and acquisitions. In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more

Tax Reform Legislation Reverses Grecian Magnesite Mining, Adds New Withholding Tax

New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions. On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more

Grecian Magnesite Mining: Impact on Investments by Non-US Investors in US Funds

US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more

FDA Clarifies Consent Requirements for Certain Minimal Risk Clinical Investigations

FDA’s guidance, which permits institutional review boards to waive informed consent for certain clinical investigations, may facilitate valuable personalized medicine research....more

Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event. On August 6, the US Treasury...more

New York Issues Tax Advisory Opinion Regarding Cloud Computing Product

The new guidance addresses the New York sales and use tax treatment of cloud computing services. Background - On April 14, the New York State Department of Taxation and Finance (the Department) issued Advisory...more

U.S. Supreme Court Holds DMA’s Action Is Not Barred By Tax Injunction Act

The U.S. Supreme Court unanimously held that the Tax Injunction Act does not bar Direct Marketing Association’s federal court challenge to Colorado’s sales and use tax notice and reporting requirements....more

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

The IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more

Initial FATCA Registration/Withholding Dates Draw Near

Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms. The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more

4/11/2014  /  FATCA , FATCA Timeline , FFI , IRS

New Accounting Rules for Gift Cards Redeemable by Unrelated Entities

IRS modifies rules allowing the deferral method of accounting for advance payments received for the sale of gift cards that are redeemable by an unrelated party. On July 24, the Internal Revenue Service (IRS) released an...more

Treasury Revises FATCA Implementation Timeline

IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...more

7/16/2013  /  Delays , FATCA , FFI , Foreign Banks , IGAs , IRS , Tax Reform , U.S. Treasury
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