On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more
7/5/2024
/ Corporate Taxes ,
Domestic Corporations ,
Excise Tax ,
Internal Revenue Code (IRC) ,
Investment Companies ,
Investment Company Act of 1940 ,
IRS ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Stock Repurchases ,
U.S. Treasury
On February 11, 2022, in a letter addressed to certain U.S. Senators, the U.S. Department of the Treasury indicated that cryptocurrency miners, cryptocurrency stakers or related hardware or software providers would not be...more
2/17/2022
/ Bitcoin ,
Bitcoin Mining ,
Brokers ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Infrastructure Investment and Jobs Act (IIJA) ,
Investment ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury ,
Virtual Currency
The U.S. Department of the Treasury and the Internal Revenue Service on December 30, 2021, issued final regulations (“Final Regulations”) allowing a tax-free treatment of “covered modifications,” as defined, of certain...more
1/31/2022
/ Contract Modification ,
Debt Instruments ,
Derivatives ,
FATCA ,
Financial Regulatory Reform ,
Insurance Contracts ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
IRS ,
Leases ,
Libor ,
New Regulations ,
REMIC ,
Stocks ,
Tax-Free Transfers ,
U.S. Treasury
On November 30, 2021, the U.S. Internal Revenue Service issued Revenue Procedure 2021-53, temporarily allowing publicly offered regulated investment companies (RICs), including certain business development companies (BDCs)...more
As we recently noted in our OnPoint dated October 20, 2021, the rise in interest from retail and institutional investors in the cryptocurrency market has attracted increased regulatory and enforcement attention in the past...more
11/17/2021
/ Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Enforcement Priorities ,
Financial Transactions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Virtual Currency
On August 27, 2020, the Internal Revenue Service issued a memorandum (“Memorandum”) (see link) allowing taxpayers and their representatives to temporarily use an electronic or digital signature when signing certain tax forms...more
The U.S Department of the Treasury and the Internal Revenue Service on June 24, 2020 issued final tax regulations ("Final Regulations") that permit a regulated investment company (“RIC”) to report to its shareholders the...more
7/11/2020
/ Dividends ,
Final Rules ,
Investment Companies ,
IRS ,
Pass-Through Entities ,
Real Estate Investments ,
REIT ,
RICs ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions
On May 4, 2020, the U.S. Internal Revenue Service issued Revenue Procedure 2020-19, temporarily allowing publicly offered regulated investment companies (RICs), including certain business development companies and certain...more
5/13/2020
/ Business Development Companies ,
Cash Transactions ,
Closed-End Funds ,
IRS ,
New Guidance ,
Publicly-Traded Companies ,
REIT ,
RICs ,
Securities and Exchange Commission (SEC) ,
Shareholder Distributions ,
Stocks
Key Takeaways
- Registered closed-end funds and business development companies should reassess their distribution policies if they are in need of liquidity.
- As part of that reassessment, funds should consider paying...more
4/8/2020
/ Business Development Companies ,
Closed-End Funds ,
Coronavirus/COVID-19 ,
Distribution Rules ,
Dividends ,
Investment Funds ,
IRS ,
Liquidity ,
Relief Measures ,
Tax Deductions ,
Tax Relief
In the wake of the Coronavirus pandemic, on March 18, 2020 the U.S. Internal Revenue Service issued guidance extending the Federal income tax payment deadline for any person with a Federal income tax payment otherwise due...more
On October 9, 2019, the U.S. Department of the Treasury and the Internal Revenue Service proposed regulations (“Proposed Regulations”) addressing the transition from London interbank offered rate (“LIBOR”) to the use of...more
10/11/2019
/ Comment Period ,
Debt Instruments ,
Foreign Banks ,
Hedges ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
IRS ,
Libor ,
Proposed Amendments ,
Proposed Regulation ,
REMIC ,
Secured Overnight Funding Rate (SOFR) ,
Sterling Overnight Index Average (SONIA) ,
Treasury Regulations ,
U.S. Treasury ,
Variable Rates
The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more
7/23/2019
/ Business Taxes ,
Corporate Taxes ,
Exceptions ,
Foreign Corporations ,
Foreign Insurance Companies ,
Income Taxes ,
Investors ,
IRS ,
New Guidance ,
Partnerships ,
Passive Investments ,
PFIC ,
Proposed Regulation ,
U.S. Treasury
On March 18, 2019, the U.S. Department of the Treasury and the Internal Revenue Service issued final tax regulations for registered investment funds that are taxed as regulated investment companies (“RICs”) and that invest in...more
3/26/2019
/ Closed-End Funds ,
Commodities ,
Controlled Foreign Corporations ,
Derivatives ,
Dividends ,
Exchange-Traded Products ,
Final Rules ,
Foreign Subsidiaries ,
GILTI tax ,
Imputed Income ,
Investment Company Act of 1940 ,
Investment Funds ,
IRS ,
Mutual Funds ,
Private Letter Rulings ,
Registered Investment Companies (RICs) ,
Securities ,
Stocks ,
Subsidiaries ,
Tax Legislation
On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more
12/19/2018
/ Common Reporting Standard (CRS) ,
FATCA ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
IRS ,
Mutual Funds ,
Non-Residents ,
OECD ,
Private Funds ,
Proposed Amendments ,
Regulatory Burden ,
U.S. Treasury ,
Withholding Requirements
The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more
12/8/2017
/ Asset Seizure ,
Burden of Proof ,
Constitutional Challenges ,
Digital Currency ,
Enforcement Actions ,
Extraterritoriality Rules ,
IRS ,
Popular ,
Right to Privacy ,
Summons ,
Tax Evasion ,
Virtual Currency