Following the US Supreme Court’s denial of cert in Nextel, taxpayers with protective refund claims held pending the ultimate outcome of Nextel will need to re-evaluate their claims as Pennsylvania begins to address them...more
The US Supreme Court agreed to hear South Dakota’s challenge to Quill Corp. v. North Dakota, setting the Court up to decide whether a retailer with no physical presence in a state is required to collect and remit sales and...more
Federal tax reform will have a significant and possibly unexpected impact on state taxes, including on individual deductions and, for corporations, reporting methods and limitations regarding net operating losses and interest...more
New tax provisions have significant impact on structuring mergers and acquisitions.
In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions.
On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more
Victims of Hurricane Irma located in areas designated by the Federal Emergency Management Agency as qualifying for individual assistance now have until January 31, 2018 to file certain federal tax returns and make certain...more
Victims of Hurricane Harvey in some designated areas now have until January 31, 2018 to file certain federal tax returns and make payments....more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more
The IRS has issued Revenue Procedure 2017-45, which provides that certain distributions of stock by a publicly offered RIC or publicly offered REIT made pursuant to a “cash or stock election” will be treated as a taxable...more
Ohio Supreme Court decides physical presence is not a necessary condition for imposing commercial activity tax.
The Ohio Supreme Court recently ruled that Ohio may impose its commercial activity tax (CAT) on...more
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more
The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more
5/24/2016
/ Diversification Requirements ,
Floating NAV ,
Income Taxes ,
Insurance Industry ,
Internal Revenue Code (IRC) ,
IRS ,
MMF ,
Money Market Funds ,
Registered Investment Companies (RICs) ,
RICs ,
Securities and Exchange Commission (SEC)
IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more
The U.S. Supreme Court unanimously held that the Tax Injunction Act does not bar Direct Marketing Association’s federal court challenge to Colorado’s sales and use tax notice and reporting requirements....more