In Revenue Procedure 2016-37, the IRS formally announced the elimination, effective January 1, 2017, of the five-year remedial amendment cycle system for individually designed, qualified retirement plans.[1] The IRS further announced that it would publish each year a Required Amendments List (“RA List”) and provide an Operational Compliance List (“OC List”) in place of the […]
On November 1, 2016, the Internal Revenue Service (“IRS”) issued Notice 2016-66, identifying certain transactions relating to “micro-captive” insurance companies as “transactions of interest.” This designation brings covered captive insurance companies into a Federal reporting regime requiring participants in such transactions, as well as their advisors, to meet certain one-time and annual filing obligations. Participants […]
This past weekend, President Donald Trump signed an Executive Order requiring all new appointees in his Administration to sign an ethics pledge that contains special “revolving door” and gift restrictions. Although Mr. Trump also formally rescinded an ethics order issued in the early days of the Obama presidency, this new Executive Order carries over some […]
Circuit Split on Class Action Waivers The U.S. Supreme Court has agreed to review the validity of class action waiver clauses in employment arbitration agreements to resolve a conflict among the federal appellate courts. As our firm has explained in prior blog posts, the U.S. Court of Appeals for the Ninth Circuit – the federal […]
In Revenue Procedure 2016-37, the IRS formally announced the elimination, effective January 1, 2017, of the five-year remedial amendment cycle system for individually designed, qualified retirement plans.[1] The IRS further announced that it would publish each year a Required Amendments List (“RA List”) and an Operational Compliance List (“OC List”) in place of the Cumulative […]
On December 12th, the IRS issued final regulations requiring foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners by obtaining a U.S. tax identification number (“TIN”) and in many circumstances, filing annual returns. Wealth advisors and their clients should be aware that failure to comply could result in significant civil penalties and, if […]
It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes President-Elect Trump’s proposal and Speaker of the House Paul Ryan’s proposal on key corporate tax provisions applicable to U.S. domestic and multinational corporations. Estate, gift and generation-skipping tax proposals (including possible changes to the treatment of basis […]
President-elect Donald Trump has chosen Andrew Puzder as his Secretary of Labor, according to Trump’s transition team. Puzder is the CEO of CKE Holdings, the parent company of Carl’s Jr. and Hardee’s, and has been a vocal critic of the Obama Labor Department’s overtime regulations and efforts to increase the federal minimum wage. As labor […]
The Bipartisan Budget Act of 2015 (“BBA”) fundamentally changed the rules by which partnerships, and entities taxed as partnerships, interact with the Internal Revenue Service (“IRS”) in an audit or litigation. We outlined these significant changes to the partnership audit rules in a prior Alert. The BBA repealed the 30 year-old TEFRA partnership audit regime, […]
It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes current law, President-Elect Trump’s proposal, and Speaker of the House Paul Ryan’s proposal on key individual income tax provisions relevant to high-net-worth individuals. Estate, gift, and generation-skipping tax proposals (including possible changes to the treatment of basis […]
On January 20, 2017, President-elect Donald Trump will be inaugurated as the 45th president of the United States. Because immigration was a pivotal issue in his presidential campaign, many foreign nationals and employers are wondering what changes we can expect in U.S. immigration policy and practice under the new administration. President-elect Trump’s statements on […]
Effective January 1, 2017, the Office of Government Ethics (OGE) is revising the gift rules applicable to executive branch employees. The revisions were prompted by the Ethics in Government Act of 1978, which requires OGE to periodically update its regulations. For the most part, the revisions are non-substantive edits that enhance readability and remove gender […]