Searching Content indexed under Finance and Banking by Amanda Nussbaum ordered by Published Date Descending.
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Proposed Regulations Provide Clarity For Qualified Foreign Pension Fund Exception
On June 7, 2019, the U.S. Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") released proposed Treasury regulations under Sections 897, 1445 and 1446.
United States
12 Jul 2019
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
The Proposed BEAT Regulations
On December 13, 2018, the Internal Revenue Service and the Department of the Treasury released proposed regulations with respect to the "base erosion and anti-abuse tax" under section 59A of the Internal Revenue Code.
United States
7 Jan 2019
Summary Of The Opportunity Zone Program
The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program.
United States
14 Nov 2018
IRS And Treasury Issue Proposed Opportunity Zone Regulations
The proposed regulations answer the most pressing questions with mostly taxpayer-friendly answers.
United States
23 Oct 2018
Tax-Exempts May Limit Fund Investments Pursuant To New IRS Guidance On UBTI
On August 21, 2018, the Internal Revenue Service ("IRS") released Notice 2018-67 (the "Notice"), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6)
United States
5 Sep 2018
Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
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 certain exceptions to the annual PFIC reporting requirements (the "PFIC Regulations").
United States
21 Jan 2017
Extension Of FBAR Filing Deadline For Certain Filers
Potential filers should note that the scope of individuals covered by Notice 2016-1 is broader than that of the FBAR proposed regulations.
United States
12 Jan 2017
FBAR Filing Deadline Extended For Certain Filers
On December 16, 2016, FinCEN issued Notice 2016-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114, for certain individuals with signature or other authority over . . .
United States
9 Jan 2017
Proposed FBAR Regulations Expand Filing Exemption And Reporting Requirements
As reported in our prior client alerts, the Report of Foreign Bank and Financial Accounts, FinCEN Form 114, must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a foreign financial account if the aggregate value of all such U.S. person's foreign financial accounts exceeds $10,000 at any time during the year.
United States
11 Mar 2016
Real Estate Investments By Qualified Foreign Pension Funds After The PATH Act
The PATH Act included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts and investments by non-U.S. investors in U.S. real estate.
United States
3 Mar 2016
Significant Changes To U.S. Taxation Of REITs And Investments By Non-U.S. Investors In Real Property Under The PATH Act
On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015.
United States
3 Feb 2016
UK Summer Budget 2015 Key Issues For Asset Managers And Non-UK Domiciled Individuals
On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership), and further changes that will particularly impact UK tax-resident individuals who are not domiciled in the UK for tax purposes ("non-doms").
United States
20 Jul 2015
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