News & Analysis as of

Distribution Rules

Donor Advised Funds May Face New IRS Rules

by Faegre Baker Daniels on

On December 4, 2017, the Treasury Department and Internal Revenue Service (IRS) issued Notice 2017-73, new proposed guidance for donor advised funds (DAFs). The public has the opportunity to comment on the following proposed...more

IRS Issues Request for Comments Regarding the Regulation of Donor Advised Funds

The Internal Revenue Service (the “IRS”) has issued Notice 2017-73 (the “Notice”) which outlines approaches the Department of the Treasury (“Treasury”) and the IRS are considering with respect to the regulation of certain...more

Employee Benefits Developments - November 2017

by Hodgson Russ LLP on

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November 2017. Minimum Required Distributions – IRS Guidance for Handling Missing Participants - Missing...more

Home On The Grange

by Allen Matkins on

As a child, I was always puzzled when I saw a Grange Hall. Was Grange a misspelling of “range”? If not, what was a “grange”? Only later did I learn that “grange” was derived from the Latin word, granum, meaning a seed. ...more

Tax Treatment of Employee Hardship and Disaster Relief - Tax Update Volume 2017, Issue 6

by Pepper Hamilton LLP on

Recent hurricanes and fires have caused employers to focus on how to help employees who have been victims of disasters. Employees also suffer hardships that are not related to disasters, but that result from personal...more

New Private Letter Ruling Pilot Program - Focus on Spin-Off Transactions - Tax Update Volume 2017, Issue 6

by Pepper Hamilton LLP on

In a new 18-month pilot program, the IRS is temporarily opening up a previous no-rule policy with respect to certain issues arising in a distribution by a corporation to its shareholders under Section 355....more

How To Manage Foreign Trusts With U.S. Beneficiaries

by Carlton Fields on

Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth....more

New Tax Bill Eliminates Many Popular Individual Deductions/Exclusions, Adds Excise Tax and Clarifies IRA/Pension Provisions

On November 2, 2017, House Republicans released their highly anticipated tax reform proposal formally named the Tax Cuts and Jobs Act (the "Act"). The Act must be approved by both the House and the Senate and signed by the...more

Missing Participants and Beneficiaries and Required Minimum Distributions

by Seyfarth Shaw LLP on

Seyfarth Synopsis: The Internal Revenue Service released guidance detailing specific procedures qualified retirement plans may utilize to satisfy required minimum distribution standards for missing participants and...more

Dutch dividend withholding tax

by Hogan Lovells on

On an international front, it has been announced that the new cabinet to be established in the Netherlands intends to abolish Dutch dividend withholding tax with effect from 1 January 2019. ...more

Additional Hurricane Relief for Retirement Plan Participants Makes Landfall

On September 29, 2017, the Disaster Tax Relief and Airport and Airway Extension Act of 2017 (the “Act”)1 was signed into law to provide aid to victims who are recovering from the recent hurricanes in August and September...more

End and refund of the French 3% tax on distributions

by White & Case LLP on

The French Constitutional Court rules that the 3% contribution on distributions is unconstitutional - On 6 October, 2017, the French Constitutional Court, in its decision (n°2017-660 QPC), held that the 3% contribution on...more

Revised rule for securities distributions outside of Canada

by DLA Piper on

On June 29, 2017, the Ontario Securities Commission published for comment a revised OSC Rule 72-503 Distributions Outside Canada and its proposed Companion Policy (collectively, the “Revised Rule”). The comment period for the...more

IRS Resumes Issuing Transactional Spin-Off Rulings

by Proskauer - Tax Talks on

On September 21, 2017, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2017-52 (the “Rev. Proc.”), introducing an 18-month “pilot program” in respect of corporate “spin-off,” “split-up” and “split-off”...more

Retirement Plan and Leave Donation Programs During States of Emergencies

by Carlton Fields on

This article should interest employers offering retirement plan benefits or leave donation programs to employees affected by Hurricanes Harvey and Irma, in particular, and in various states of emergencies, in general. It...more

The NYSE Amends its Advance Notice Requirement for Dividend Announcements: NYSE Staff Now on Call 24/7

by Locke Lord LLP on

On August 14, 2017, the SEC approved a rule change to the NYSE Listed Company Manual to require listed companies to provide notice to the NYSE at least ten minutes before making any public announcement with respect to a...more

Ninth Circuit Rules That Hypothetical Preference Actions May Be Considered in Applying the Greater Amount Test

by Jones Day on

In Schoenmann v. Bank of the West (In re Tenderloin Health), 849 F.3d 1231 (9th Cir. 2017), a divided panel of the U.S. Court of Appeals for the Ninth Circuit recently addressed as a matter of apparent first impression...more

More Fund Companies Sanctioned for Misusing Fund Assets for Distribution

by Carlton Fields on

The SEC recently settled enforcement actions against William Blair and two Calvert companies for using mutual fund assets to pay distribution-related expenses in violation of Investment Company Act Rule 12b-1 and for certain...more

Split Payment le nuove disposizioni contenute nella cd Manovrina 2017

L'art. 1 del D.L. 50/2017, convertito con Legge 96/2017 pubblicata in G.U. del 23 giugno 2017, ha introdotto nel Decreto IVA (DPR 633/1972) nuove disposizioni in materia di scissione dei pagamenti (di seguito anche "Split...more

UK Tax Round Up - July 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

US Supreme Court confirms priority rules apply to a structured dismissal of a chapter 11 bankruptcy case

by DLA Piper on

In its recent decision Czyzewski v. Jevic Holding Corp., 137 S. Ct. 973 (2017), the United States Supreme Court held that a bankruptcy court may not approve a structured dismissal of a chapter 11 case that provides for...more

The Rosenbaum Law Firm Review - June 2017

by Ary Rosenbaum on

Free Advice For 401(k) Plan Sponsors. Yes, it's free. They always say there is no such thing as a free lunch because most of the time, free has strings attached. Even when it comes to retirement plans, that free plan...more

Collocamento diretto di azioni: La piattaforma di Borsa Italiana del mercato secondario a servizio del primario

by Latham & Watkins LLP on

Dal 3 luglio 2017 è possibile utilizzare la piattaforma del mercato secondario oltre che per le obbligazioni anche per l’offerta di azioni. Nuove opportunità per le offerte retail con nuovi ruoli (e responsabilità) per lo...more

Let Former Employees Roll Their Money Out

by Ary Rosenbaum on

One of the rules I live by is that I believe that you should never let someone who dislikes you be in a position where they can hurt you. Let’s just say that I worked for someone who should have taken that advice. That is why...more

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

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