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 […]
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 The BBA repealed the 30 year-old TEFRA partnership audit regime, […]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 […]
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 […]
On November 1, 2016, the Internal Revenue Service (“IRS”) issued Notice 2016-66 identifying certain transactions relating to small captive insurance companies as a “transaction of interest.” Prior to this notice, the IRS had identified certain small captives as amongst its list of “Dirty Dozen Tax Scams.” Also, the IRS has been actively examining captives and […]
IR Global, the world’s largest exclusive network of advisory firms is delighted to introduce S. Fay Sulley of Torkin Manes LLP. S. Fay Sulley has joined IR as our exclusive Insolvency Member in Canada – East. For more than three decades, Torkin Manes has applied the law to resolve issues standing in the way of our clients’ goals. […]
On October 4, 2016, the Treasury Department and Internal Revenue Service (IRS) issued revised regulations governing how recourse partnership liabilities are allocated among partners. These temporary regulations, which are binding on taxpayers immediately, relate to so-called “bottom-dollar payment obligations” (BDPOs). Generally, if a partner guarantees a recourse partnership liability, the liability will be allocated to […]
IR Global, the world’s largest exclusive network of advisory firms is delighted to introduce Ruben Mooneesawmy of Axcel Insights Ltd. Ruben has joined IR as our exclusive Insolvency Member in Mauritius. Axcel Insights was formed in 2016 when Ruben spotted a significant gap on the restructuring market in Mauritius. The firm also provides M&A advice thanks to […]
Benchmark Litigation lists Caplin & Drysdale’s Complex Litigation Group as “recommended” in the District of Columbia for 2016, the Group’s seventh year in the publication. Lawyers earning special recognition include Trevor W. Swett III, who continues to earn “local litigation star” status, and “future stars” Jeffrey A. Liesemer, Kevin C. Maclay, and James P. Wehner. […]
Introduction Chapter 15 of the Bankruptcy Code, which deals with cross-border insolvency cases, took effect nearly 11 years ago.(1) Congress enacted Chapter 15 in 2005 to replace Bankruptcy Code Section 304, which previously addressed transnational insolvencies.(2) Chapter 15 largely incorporates the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Cross-Border Insolvency, which […]
IR Global, the world’s largest exclusive network of advisory firms is delighted to introduce John Ames of Bingham Greenebaum Doll LLP. John has joined IR as our exclusive Insolvency Member in US-Kentucky. Bingham Greenebaum Doll LLP is a business law firm providing transactional, litigation and government services to clients ranging from Fortune 500 businesses and Global 1000 […]