What is an EIN? An EIN is a federal tax ID number for an entity, estate, trust, or other organization. For example, the following are generally required to obtain an EIN: partnerships, limited liability companies (“LLC”),...more
As discussed in detail below, the Corporate Transparency Act (CTA) provides an exemption to its reporting requirements for certain large operating companies (the Large Operating Company Exemption or “LOC Exemption”). In order...more
A variety of businesses, such as LLCs, LLPs, partnerships, and corporations, formed before January 1, 2024, have until January 1, 2025, to file their initial report with the Department of Treasury’s Financial Crimes...more
Plan sponsors of Code Section 403(b) tax-sheltered annuity plans (“403(b) plans”) that have not already done so may want to consider applying for an IRS determination letter or planning and budgeting for the process next year...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 24, 2024, issued two new FAQs providing guidance on 1) how to obtain a taxpayer identification number (TIN) in a manner to ensure...more
Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more
This is the second in a two-part series discussing the Corporate Transparency Act (CTA) – new legislation enacted by Congress in January 2021, as part of the Anti-Money Laundering Act of 2020. Read the first part of this...more
A federal law adopted in 2021 takes effect on January 1, 2024, and imposes reporting obligations on many entities that may not be accustomed to reporting much information. This article provides a brief overview of the law,...more
On October 21st, the IRS announced changes to its qualified plan determination letter program. Most notably, the program has been expanded to include section 403(b) tax-sheltered annuity plans (“403(b) plans”). Although...more
In Revenue Procedure 2022-40, the IRS recently expanded the determination letter program to allow applications by individually-designed 403(b) plans. This expansion will allow 403(b) plan sponsors to request a determination...more
The IRS has had a determination letter process for qualified plans under Code section 401(a), like 401(k) and other defined contribution plans, for many years. A favorable IRS determination letter would give the sponsoring...more
The IRS has issued guidance that for the first time permits companies to apply for determination letters for individually-designed 403(b) Plans. Under the new guidance, determination letters will be available for 403(b) plans...more
The story of the year has been the coronavirus. COVID-19 has dominated news headlines, social media, and virtually every aspect of our lives. The virus has likewise dominated legal and tax news. Lawmakers and agencies have...more
Current closures at the Internal Revenue Service (“IRS”) have caused significant delays in obtaining an Employer Identification Number (“EIN”) for some U.S. businesses formed by Canadians, including new U.S. subsidiaries...more
With data breaches becoming a common event throughout the world, the Internal Revenue Service (“IRS”) has been undertaking a number of initiatives aimed at enhancing its security of taxpayer information and preventing the...more
Can a foreign individual without an Individual Taxpayer Identification Number (“ITIN”) serve as the “responsible party” to obtain a U.S. Employer Identification Number (“EIN”)? ...more
Effective May 13, 2019, the Internal Revenue Service (IRS) changed the requirements for obtaining an employer identification number (EIN}. The IRS no longer permits an entity to be named as the “responsible party” on IRS Form...more
An entity operating in the U.S. needs a U.S. Federal employer identification numbers (“EIN”) in order to open a bank account in the United States, act as an employer, file a tax return and complete certain other corporate...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more
The IRS’ new policy regarding employer identification numbers (“EINs”) could significantly delay the formation of new entities, especially by non-U.S. persons, unless practitioners and their clients get very proactive. ...more
As we have all been scrambling to get our taxes completed this month, a new IRS requirement may have been overlooked that goes into effect on May 13, 2019. This new requirement impacts the process by which any new entity...more
The Internal Revenue Service announced that it has revised the Employer Identification Number application process in order to provide greater security and improve transparency. The revision will require that each applicant’s...more
French investments in the U.S. vary largely in terms of scale and nature, but whatever it is a small French startup only creating an even smaller U.S. subsidiary or a large French corporation acquiring and restructuring an...more
In an announcement that was overshadowed by the significant tax legislation enacted in December, 2017, the IRS has released updated instructions for its Form SS-4, Application for Employer Identification Number (EIN). This...more
The Internal Revenue Service issued new instructions for the Employer Identification Number application process in December 2017. Unless an applicant is a government entity, the applicant’s “responsible party” must now be an...more