News & Analysis as of

U.S. Treasury Reporting Requirements

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

FinCEN Action Demonstrates the Agency’s Ability to Use Anti-Money Laundering Laws Against Non-U.S. Entities

On Wednesday, July 27, 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $110 million fine levied against BTC-e, a digital currency exchange, for BTC-e’s alleged refusal to abide by...more

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

by Latham & Watkins LLP on

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

TIC Form SHC Deadline Approaching to Report U.S. Ownership of Foreign Securities

The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC) data reporting system. Form SHC is the mandatory five-year...more

Reporting by private funds on Treasury Form SHC

by DLA Piper on

Every five years, the Department of the Treasury conducts a benchmark survey on the ownership of foreign securities by US residents. This data is collected on Form SHC and is next due on March 3, 2017, covering relevant...more

TIC Form SHC Deadline Approaching to Report U.S. Ownership of Foreign Securities

by Proskauer Rose LLP on

Form Deadline Is March 3, 2017 - Introduction - The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC)...more

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

by Proskauer Rose LLP on

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

Upcoming Deadline for Form SHC - Holdings of Foreign Securities

by Ropes & Gray LLP on

Recently, the Department of the Treasury released the final instructions for the reporting requirements of the Treasury International Capital Benchmark Form SHC (herein referred to as “Form SHC”) for the 2016 calendar year....more

Lawsuit filed to set aside IRS Notice 2016-66

by Womble Bond Dickinson on

Two months ago, without any prior warning or public notice, the IRS issued Notice 2016-66 which defined a number of common captive insurance transactions as “transactions of interest.” The Notice is limited to captive...more

36-Month Rule for Reporting Discharges of Indebtedness Is Repealed

by Shipman & Goodwin LLP on

The Treasury Department has issued proposed amendments to the regulations governing the reporting of discharges of indebtedness that will impact the filing of Forms 1099-C by member banks for the 2016 calendar year. In...more

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

by Dechert LLP on

TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

by Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more

There is life after death...of the Bottom-Dollar Guarantee

by Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

IRS Proposed Regulations Under Section 305(c)

by Proskauer - Tax Talks on

In April, the IRS issued proposed regulations interpreting deemed distributions under Section 305(c). Specifically, the proposed regulations would clarify the amount and timing of deemed distributions that result from an...more

Treasury to Propose Legislation Requiring Beneficial Ownership Reporting At Time of Entity Formation

The U.S. Department of the Treasury has announced its intention to propose legislation requiring reporting of beneficial ownership at the time a new entity is formed. According to Treasury: “The Administration is...more

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

BEA Proposes Changes to Reporting Requirements for Private Funds

by Dechert LLP on

The Bureau of Economic Analysis (BEA), in collaboration with the U.S. Department of the Treasury (Treasury Department) and the Federal Reserve Bank of New York, has proposed changes to certain cross-border investments that...more

Fiduciary Alert: IRS Again Extends Time for Consistent Basis Reporting via Form 8971 until June 30, 2016

by Tucker Arensberg, P.C. on

Effective March 23, 2016, the Treasury Department and Internal Revenue Service published Notice 2016-27, once again extending, until June 30, 2016, the deadline for executors and other persons to complete and file Form 8971...more

Consistent Basis Reporting Update: Treasury Issues Proposed Rules on Portability Returns, Final Values, and After-Discovered...

by Williams Mullen on

On March 4, 2016, the U.S. Department of the Treasury released both temporary and proposed regulations (the “Proposed Regulations”) on the consistent basis and reporting requirements between a decedent’s estate and persons...more

IRS Postpones Filing Deadline for New Basis Reporting Requirements Again

by Bryan Cave on

As part of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, signed into law by President Obama on July 31, 2015, Sections 1014(f) and 6035 were enacted. Section 1014(f) provides rules...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 23 of 24): Notice 2016-4 Postpones Reporting and...

Under the Affordable Care Act’s reporting requirements that have been the subject of this series, statements to responsible individuals (a/k/a “employees”)—i.e., Forms 1095-B and 1095-C—must be furnished on or before January...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

by Morrison & Foerster LLP on

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

MoFo Tax Talk - Volume 8, No. 3

by Morrison & Foerster LLP on

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

65 Results
|
View per page
Page: of 3
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.