Reports Due by the End of June -
Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2013 must electronically file with the U.S. Treasury...more
On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more
Every foreign entity must take steps immediately to determine whether FATCA will apply to it and, if so, whether FATCA registration will be required by April 25, 2014....more
On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more
On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more
In September 2013, Massachusetts enacted legislation to retroactively repeal the extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and software modification services...more
In January 2013, Congress enacted legislation that could provide certain investors who acquire qualified small business stock (“QSBS”) before the end of 2013 with a significant tax benefit. In effect, the gains realized from...more
On September 27, 2013, Massachusetts Governor Deval Patrick signed legislation to retroactively repeal the recent extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and...more
In light of last week’s news that Massachusetts lawmakers intend to retroactively repeal the controversial “tech tax”, the Massachusetts Department of Revenue (“MDOR”) yesterday announced that it is deferring the September 20...more
On September 12, 2013, Massachusetts legislators announced their intention to repeal (with retroactive effect) the recent expansion of the 6.25 percent Massachusetts sales and use tax to certain types of previously untaxed...more
On August 19, 2013, the IRS began to accept applications for registration under FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, by requiring foreign financial institutions (“FFIs”),...more
On July 12, 2013, the IRS issued new guidance regarding FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers. In particular, the IRS (1) revised certain elements of the timeline for FATCA...more
Offshore Master with U.S. and Offshore Feeders -
This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more
Reports Due Before the End of June -
Every U.S. person that had a financial interest in, or signature authority over, a foreign financial account during 2012 must file U.S. Treasury Form TD F 90-22.1, Report of Foreign...more
This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more
Yesterday, President Obama issued his Administration’s Fiscal Year 2014 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more
Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more
U.S. Funds with Only U.S. Investors -
FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more
On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”).
Among its provisions, the Act extends a tax benefit whereby capital gains from the sale or exchange of certain...more