Jonathan Sambur

Eversheds Sutherland (US) LLP

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Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

5/17/2024 / Business Entities , Domestic Corporations , Final Rules , Financial Regulatory Reform , Foreign Persons , IRS , Proposed Regulation , Registered Investment Companies (RICs) , Regulatory Agenda , U.S. Treasury

E-Filing threshold for information returns to be reduced starting with 2024 filings

On February 21, 2023, Treasury and the IRS issued T.D. 9972, finalizing regulations implementing the requirement to e-file certain information and tax returns. These regulations affect filers of partnership returns, corporate...more

4/4/2023 / Business Taxes , Corporate Taxes , E-Filing , Exemptions , Filing Requirements , Final Rules , IRS , Tax Returns , U.S. Treasury , Waivers

Pulling back the curtain: FinCEN finalizes ultimate beneficial owner reporting rule

Certain companies will soon have to give the Financial Crimes Enforcement Network (FinCEN) a look behind the corporate veil. In December 2021, FinCEN issued a Notice of Proposed Rulemaking (NPRM) seeking comment on one...more

10/12/2022 / Anti-Money Laundering , Beneficial Owner , Corporate Transparency Act , Customer Due Diligence (CDD) , Final Rules , Financial Institutions , FinCEN , Reporting Requirements

IRS extends relief for Section 871(m) regulations

Last week, the Internal Revenue Service (IRS) issued Notice 2022-37, which further extends the phase-in period for compliance with final regulations under sections 871(m), 1441, 1461, and 1473 regarding dividend...more

8/31/2022 / Derivatives , Dividend-Equivalent Transactions , Final Rules , IRS , Qualified Derivatives Dealers (QDDs) , Section 871(m)

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