In a memorandum titled "In Wake of the Panama Papers, Treasury Proposes New Reporting Requirements for Foreign-Owned Legal Entities," Cadwalader attorneys examined Treasury-proposed regulations that would require business entities formed in the United States, that are owned by a single foreign person, to obtain an employer identification number and to file annual information returns with the IRS. The attorneys noted that while the proposed regulations will not change the tax treatment of these legal entities, they will supply the IRS with additional information about the entity, its foreign owner and other foreign related parties. The attorneys observed that these proposed regulations are a further effort by the Obama Administration to increase global transparency and require reporting by anonymous foreign-owned entities, particularly in light of the recent release of the "Panama Papers."
Click here to view the Cadwalader memorandum authored by Linda Swartz, Mark Howe, Joseph Moreno, Jodi Avergun, Keith Gerver and Kendra Wharton.
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