The various forms of information reporting required by the Internal Revenue Code form the backbone of both voluntary compliance with tax laws and the starting point for audits by the Internal Revenue Service (IRS). One form...more
4/17/2024
/ Business Taxes ,
Cannabis-Related Businesses (CRBs) ,
Cash Transactions ,
Controlled Substances ,
Dispensaries ,
Fifth Amendment ,
Internal Revenue Code (IRC) ,
IRS ,
Marijuana Related Businesses ,
Reporting Requirements ,
Required Forms ,
Retail Market ,
Tax Liability
Summary -
On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is...more
Taxpayers have long attempted to limit the application of the Self-Employment Contributions Act (SECA ) taxes to income that is akin to employment income and not investment, or passive income, by relying on Code §1402(a)(13)....more
Introduction and Background -
Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
8/17/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
In Notice 2020-23, released on April 9, the Department of the Treasury expanded the relief offered in earlier notices to apply to a broader set of taxpayers, additional tax returns and tax payments required to be filed or...more
In Notice 2020-18, released on March 25, the Department of the Treasury announced that any person with a federal income tax payment or federal income tax return due on April 15, 2020 has until July 15, 2020 to make the...more
March 20 Update -
Secretary Mnuchin tweeted that the Department of the Treasury will be moving “Tax Day from April 15 to July 15 this year.” When the official Treasury Notice is released, we will update this document with...more
Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more
5/8/2019
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Credit Facilities ,
Creditors ,
Dividends ,
IRS ,
New Rules ,
Proposed Regulation ,
Section 956 ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
The U.S. federal taxation of non-U.S. persons who transfer interests in partnerships has a long and storied history. The government staked out its position in 1991, effectively providing that a non-U.S. partner should be...more
Section 385 Proposed Regulations — Impact on Related-Party Financing -
Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more
12/13/2016
/ Audits ,
Bifurcation ,
Change of Ownership ,
Debt ,
Debt Instruments ,
Device Test ,
Equity ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Operating Losses ,
Partnerships ,
REIT ,
Revenue Procedure 2016-40 ,
Safe Harbors ,
Section 355 ,
Section 385 ,
Stocks ,
Tax-Free Spin-Offs
FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more
7/15/2013
/ Deferred Action ,
Dividends ,
FATCA ,
FATCA Timeline ,
FDAP ,
FFI ,
Foreign Banks ,
IGAs ,
IRS ,
Reporting Requirements ,
Withholding Requirements
In December, Bank Leumi le-Israel BM issued a letter notifying its U.S. account holders about the IRS Offshore Voluntary Disclosure Initiative (the OVDI). The IRS OVDI is a type of amnesty program under which U.S. citizens...more
In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more