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Documents on Taxation, Banking & Financial Services
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|Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance|
Paul J. Ahn, Michael Greenberg, David D. Luce, Gerald Rokoff; DLA Piper (Canada) LLP;
September 10, 2015, previously published on July 1, 2015Senator 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.
|June 30th Deadline to File Foreign Bank and Financial Account Report (“FBAR”)|
William A. Buck; Leech Tishman;
June 26, 2015, previously published on June 2015U.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...
|US Congress Passes 1-year Retroactive "Extenders" Package|
Kathryn L. Anderson, John L. Harrington, Marc D. Teitelbaum; Dentons Canada LLP;
March 27, 2015, previously published on December 17, 2014It'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...
|Foreign 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;
March 27, 2015, previously published on January 26, 2015On 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...
|Financial Institution Cannot Assign Loans Based on Activities of Third Parties, Says Massachusetts Supreme Judicial Court|
Zachary Atkins, Prentiss Willson; Sutherland Asbill Brennan LLP;
February 26, 2015, previously published on February 25, 2015The 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...
|Bank 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;
February 17, 2015, previously published on January 12, 2015These 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.
|Florida: Pre-filed Bills Propose Tax Cuts in Three Areas|
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
February 13, 2015, previously published on December 11, 2014At 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...
|New Federal Law Allows Savings Accounts for Individuals with Disabilities|
Michael A. Bush; Bowles Rice LLP;
February 9, 2015, previously published on January 13, 2015Effective January 1, 2015, the Achieving A Better Life Experience Act (ABLE), a new federal law, provides another tool for special needs planning.
|New IRS Streamlined Filing Procedures Expands Eligibility to Us Residents and Foreign Residents|
Shannon Smith Retzke; Withers Bergman LLP;
November 28, 2014, previously published on November 20, 2014For the first time, the Internal Revenue Service (IRS) streamlined filing procedures are available to US resident taxpayers who have unreported foreign income or financial accounts. The new streamlined procedures also eliminate the risk assessment process associated with the old streamlined...
|Ignoring IRS Notice of Deficiency May Leave Taxpayer With No Recourse for Contesting Tax Liability|
Jill Misener, David J. Moise; Withers Bergman LLP;
November 28, 2014, previously published on November 20, 2014The 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...