The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 24, 2024, issued two new FAQs providing guidance on 1) how to obtain a taxpayer identification number (TIN) in a manner to ensure...more
8/2/2024
/ Beneficial Owner ,
Corporate Transparency Act ,
Disregarded Entities ,
Employer Identification Number (EIN) ,
FinCEN ,
IRS ,
Popular ,
Reporting Requirements ,
Required Forms ,
Taxpayer Identification Number ,
U.S. Treasury
The Corporate Transparency Act (CTA) is the gift that keeps giving. As affected entities and their advisers struggle to determine whether they are subject to the beneficial ownership information (BOI) reporting provisions of...more
4/30/2024
/ Beneficial Owner ,
Constitutional Challenges ,
Corporate Counsel ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Criminal Code ,
Department of Justice (DOJ) ,
Fifth Amendment ,
FinCEN ,
Fourth Amendment ,
Homeowners Association (HOA) ,
Penalties ,
Proposed Legislation ,
Reporting Requirements ,
Small Business ,
Trusts ,
U.S. Treasury
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more
2/27/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Cash Transactions ,
Corporate Transparency Act ,
FinCEN ,
Geographic Targeting Order ,
GTO ,
NPRM ,
Proposed Regulation ,
Real Estate Transfers ,
Reporting Requirements ,
Residential Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
Title Insurance ,
Trusts ,
U.S. Treasury
As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule on Sept. 29, 2022, implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more
10/7/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Officers ,
Directors ,
Domestic Corporations ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Foreign Corporations ,
Reporting Requirements ,
Securities Exchange Act ,
U.S. Treasury
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty). It provides for purposes of...more
8/9/2021
/ EU ,
Foreign Equivalency Determination ,
International Tax Issues ,
IRS ,
Member State ,
NAFTA ,
Tax Treaty ,
U.S. Treasury ,
UK ,
UK Brexit ,
United States-Mexico-Canada Agreement (USMCA)
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
6/11/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020. This compares to the previous annual record…...more
Highlights -
• In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more
7/15/2019
/ Controlled Foreign Corporations ,
Domestic Partnership ,
GILTI tax ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Minority Shareholders ,
New Guidance ,
New Regulations ,
Pass-Through Entities ,
Passive Foreign Investment Company ,
S-Corporation ,
Stocks ,
Subpart F ,
U.S. Treasury