Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast
Navigating the Once-Obscure German Nonresident Withholding Tax
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Cum-Ex Dividend Trade Investigations
The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more
Withholding Under Code Sections 1446(a) and 1446(f) A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more
The New York State Bar Association Tax Section (the “NYSBA”) has asked the government to provide guidance on the procedure for filing a protective return in respect of withholding tax in response to YA Global Investments, LP...more
On May 22, 2024, the IRS issued Notice 2024-44, which once again extends the phase-in for Section 871(m) withholding. Broadly speaking, foreign persons may be subject to a 30% withholding tax under Section 871(m) on certain...more
On May 22, 2024, the US Department of Treasury and the IRS issued two important notices—one delaying the full implementation of the withholding rules on dividend equivalent payments, and the other on derivative reporting for...more
Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more
For an employee who is a U.S. taxpayer, both the employer and the employee are liable for a portion of Social Security taxes and Medicare taxes (collectively referred to as “FICA” taxes) on the employee’s compensation. ...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
In January 2022, the Internal Revenue Service (IRS) changed the withholding election rules applicable to distributions from pension plans (a term that includes 401(k) plans, money purchase pension plans and defined benefit...more
It’s wonderful to be part of a successful business, especially in a strong economy. The owners are probably enjoying a more than just decent return on their investment and, in most cases, are getting along well enough. The...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 17, 2023 – July 21, 2023....more
On June 9, 2023, the IRS released OCC Memo 202323006, which advises that wellness indemnity payments under a fixed indemnity insurance policy are wages for purposes of Federal Insurance Contributions Act (FICA) taxes, Federal...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 12, 2023 – June 16, 2023...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more
El intercambio automático y masivo entre el fisco de Estados Unidos y otros países empezó con la ley de cumplimiento fiscal de cuentas extranjeras (Foreign Account Tax Compliance Act o FATCA). FATCA es parte de una larga...more
Retirement plan sponsors need to utilize updated Form W-4P (for periodic pension and annuity payments) and new Form W-4R (for nonperiodic payments and eligible rollover distributions) for income tax withholding elections...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 17, 2022 – October 21, 2022...more
One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more
On August 23, 2022, the IRS issued Notice 2022-37, which once again extends the phase-in of withholding under Section 871(m). Broadly speaking, foreign persons may be subject to a 30% withholding tax under Section 871(m) on...more
During the 2022 tax filing season, many taxpayers had an unpleasant surprise when they filed their tax return and found out they were getting a much smaller refund than they were expecting, or worse, had a balance due....more
Key Points - The broader application of Section 871(m) has again been delayed, this time until January 1, 2025, and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to...more
Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more