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1
IRS Audits Target Management Fee Waivers
IRS audits are increasingly targeting private investment funds over management fee waiver arrangements that are commonly used by investment managers to convert fee income into carried interest.
United States
25 May 2017
2
Podcast - Shrink The Section 457A Tax On Hedge Fund Management And Incentive Fees And Expand Your Impact
In a recently released Ropes & Gray podcast, asset management partner Isabel Dische, tax partner Brett Robbins, and private client partner Cameron Casey discuss the effect of Section 457A ...
United States
25 May 2017
3
Illinois Bills to Watch
Just days away from the May 31 close of its regular legislative session, the Illinois General Assembly has yet to enact the comprehensive series of tax and budget reforms that were first proposed by the Illinois Senate leadership late last year.
United States
25 May 2017
4
Update On US Federal Tax Reform Proposals And Their Effect On The Renewable Energy Industry
While tax reform has been a stated focus of the Trump administration and Congress, details remain elusive.
United States
25 May 2017
5
Families Can Use A Tax-Advantaged ABLE Account To Save For Disability Expenses
Governor Charlie Baker recently announced the launch of a state sponsored Achieving a Better Life Experience (ABLE) account program that has been long awaited by disabled individuals and heir families.
United States
25 May 2017
6
Favorable Capital Gains Taxation Rates Apply To Payments For Transfer Of All Substantial Rights In Patents
The portion of a termination payment attributable to a transfer of all substantial rights in a patent may be treated as long-term capital gain and taxed at more favorable rates than ordinary income.
United States
24 May 2017
7
Section 475(f) Mark-To-Market Election
A Section 475(f) election might be beneficial for a fund experiencing losses in 2017 or possibly where a fund has significant net unrealized losses coming into 2017.
United States
24 May 2017
8
Disregarded Entity Regs Confirm Global Transparency Push
Last year, the Treasury Department proposed new reporting requirements for domestic disregarded entities with one foreign owner.
United States
24 May 2017
9
U.S. Supreme Court to Revisit Carlton, Retroactivity Doctrine
On May 22, 2017, the U.S. Supreme Court denied to hear taxpayer challenges to the retroactive application of changes to tax laws in Dot Foods v. Washington Department of Revenue, and six cases challenging Michigan's retroactive repeal of an alternative apportionment method.
United States
23 May 2017
10
Basis Planning In The Usufruct And Bare Ownership Context
As explained in an earlier article,1 a common civil law estate planning technique involves an older generation making a gift of bare ownership in an income generating asset to members of a younger generation.
United States
22 May 2017
11
Tax Reform Pushing Ahead
Despite the political controversy swirling around the firing of James Comey and the appointment of a special prosecutor, the White House and Republicans are determined to push forward with tax reform.
United States
22 May 2017
12
NAFTA In A Land Of Uncertainty
A Border Tax: Can President Trump Go It Alone?
United States
19 May 2017
13
Illinois Department Of Revenue Reaffirms Cloud-Based Services Not Taxable
In two recent General Information Letters, the Illinois Department of Revenue reaffirmed that computer software provided through a cloud-based delivery system is not subject to tax in Illinois.
United States
19 May 2017
14
SEC And NYU Dialogue On Securities Market Regulation: Recommended Measures For Improving The IPO Market
In the May 10, 2017 dialogue held by the SEC's Division of Economic and Risk Analysis and New York University's Stern School of Business, academics and industry representatives provided...
United States
19 May 2017
15
The Realist - Volume 1, Edition 2
A publication of Seyfarth Shaw's New York Real Estate Practice. The ReaList newsletter covers New York real estate news, events, and trends.
United States
18 May 2017
16
Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings On Certain Spin-Off Debt Exchanges
The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation's transfer of stock or securities of a controlled corporation...
United States
18 May 2017
17
OVDP Campaign – Declines And Withdrawals
In January, the IRS released a list of 13 audit campaigns designed to focus resources on areas of concern for the IRS examination teams.
United States
18 May 2017
18
QDOT-Ting I's And Crossing T's: Estate Tax Planning For Non-United States Citizen Spouses
Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth.
United States
18 May 2017
19
How The Super Reforms Impact US Expats
Complying with Australian superannuation reforms by 1 July will trigger not just double, but triple, taxation by the US on their superannuation contributions, earnings and distributions.
United States
18 May 2017
20
Implementing The Border Adjustment Tax: Winners & Losers
The House plan to tax imports and exempt exports is part of a tax reform package that is expected to raise more than $1 trillion to offset lower income tax rates and improve U.S. competitiveness against global rivals.
United States
18 May 2017
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