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Documents on Taxation, Banking & Financial Services

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Adobe PDFNew Tennessee Reporting Requirements for Banks and Online Payment Networks
Charles Reid Barrineau, Edward H. Brown, Joshua A. Ehrenfeld, James M. McCarten, Allen Sullivan; Burr & Forman LLP;
Legal Alert/Article
February 3, 2016, previously published on January 2016
With the start of the 2016 tax reporting season, taxpayers making certain payments to a person or entity with a Tennessee address may find that Tennessee has added to the number of information returns they need to file.


HTMLProposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance
Paul J. Ahn, Michael Greenberg, David D. Luce, Gerald Rokoff; DLA Piper (Canada) LLP;
Legal Alert/Article
September 10, 2015, previously published on July 1, 2015
Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment company or PFIC tax rules.


HTMLJune 30th Deadline to File Foreign Bank and Financial Account Report (“FBAR”)
William A. Buck; Leech Tishman;
Legal Alert/Article
June 26, 2015, previously published on June 2015
U.S. taxpayers (including individuals, corporations, and partnerships) with a financial interest in, or signature authority over, foreign (outside of U.S.) financial accounts totaling $10,000 or more at any time during the year are generally required to report such foreign financial interest to the...


Adobe PDFForeign Fund Was Engaged in a Trade or Business in the United States as a Result of Lending and Underwriting Activities
Jeffrey D. Hochberg, Donald L. Korb, Eric M. Lopata, Andrew P. Solomon, David C. Spitzer; Sullivan & Cromwell LLP;
Legal Alert/Article
March 27, 2015, previously published on January 26, 2015
On January 2, 2015, the Internal Revenue Service (the “IRS”) released Advice Memorandum 201501013 (the “Advice Memorandum”) from the Office of Chief Counsel. The Advice Memorandum concludes that a partnership was engaged in a U.S. trade or business through lending and...


Adobe PDFUS Congress Passes 1-year Retroactive "Extenders" Package
Kathryn L. Anderson, John L. Harrington, Marc D. Teitelbaum; Dentons Canada LLP;
Legal Alert/Article
March 27, 2015, previously published on December 17, 2014
It's been called "a terrible way to make tax policy" and "not that great a deal for families, individuals, and businesses"--and that's just by its supporters. Still, even though far from ideal, the "Tax Increase Prevention Act of 2014" is an early Christmas present for...


HTMLFinancial Institution Cannot Assign Loans Based on Activities of Third Parties, Says Massachusetts Supreme Judicial Court
Zachary Atkins, Prentiss Willson; Sutherland Asbill Brennan LLP;
Legal Alert/Article
February 26, 2015, previously published on February 25, 2015
The Massachusetts Supreme Judicial Court (SJC) refused to allow a taxpayer, a financial institution, to assign its loan portfolios based on the location of third-party loan servicing activities for purposes of calculating its financial institution excise tax property factor. The taxpayer earned...


HTMLBank Leumi Agreement with Department of Justice Results in Disclosure of Identities of 1,500 U.S. Account Holders
Jon Grouf, James J. Holman, Hope P. Krebs, Anthony D. Martin, Megan R. Worrell; Duane Morris LLP;
Legal Alert/Article
February 17, 2015, previously published on January 12, 2015
These developments raise many significant issues for U.S. persons with undisclosed accounts at Bank Leumi with respect to potential criminal prosecution, civil examinations and the availability of the Offshore Voluntary Disclosure Program and the Streamlined Programs for residents and nonresidents.


HTMLFlorida: Pre-filed Bills Propose Tax Cuts in Three Areas
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
February 13, 2015, previously published on December 11, 2014
At the end of Jan. 2014, Florida Gov. Rick Scott released his “It’s Your Money Tax Cut Budget” for fiscal year 2014-2015. As he repeated when he unveiled his budget, Gov. Scott’s tenure has focused on cutting taxes, reducing spending, and reducing debt. It is, therefore, not...


HTMLNew Federal Law Allows Savings Accounts for Individuals with Disabilities
Michael A. Bush; Bowles Rice LLP;
Legal Alert/Article
February 9, 2015, previously published on January 13, 2015
Effective January 1, 2015, the Achieving A Better Life Experience Act (ABLE), a new federal law, provides another tool for special needs planning.


HTMLIgnoring IRS Notice of Deficiency May Leave Taxpayer With No Recourse for Contesting Tax Liability
Jill Misener, David J. Moise; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
The US Tax Court recently held in Onyango v. Comm’r 142 T.C. 24 (2014) that a taxpayer could not contest a tax liability prior to making payment where the Internal Revenue Service (IRS) issued a valid Notice of Deficiency and the taxpayer failed to take advantage of previous opportunities to...


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