The Inflation Reduction Act (IRA), enacted in August 2022, appropriated billions of dollars in additional funding to the Internal Revenue Service (IRS). The IRS has begun allocating funds, including investing in artificial...more
10/11/2023
/ Artificial Intelligence ,
Audits ,
Compliance ,
Enforcement ,
FBAR ,
GAO ,
Hedge Funds ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Real Estate Investments
On June 26, the US Supreme Court agreed to hear the appeal of Moore v. United States, a development that reverberated throughout the world of tax. The Moore case deals with the constitutionality of the transition tax under...more
Family offices routinely create, manage, and invest in multiple entities, including corporations, limited liability companies, and partnerships. For entities formed or operating in the United States, there has never been a...more
6/9/2023
/ Beneficial Owner ,
Broker-Dealer ,
Charitable Trusts ,
Corporate Transparency Act ,
Disclosure Requirements ,
Family Offices ,
FinCEN ,
Investment Adviser ,
Investment Companies ,
Limited Liability Company (LLC) ,
Partnerships ,
Tax Exempt Entities ,
U.S. Treasury ,
Venture Capital
The Inflation Reduction Act of 2022, which was signed into law on August 16, 2022, enacted a new 1% excise tax on certain repurchases of the stock of publicly traded corporations, codified in Section 4501 of the Internal...more
1/12/2023
/ Excise Tax ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Liquidation ,
Netting Agreements ,
New Guidance ,
Private Investment in Public Equity (PIPEs) ,
Special Purpose Acquisition Companies (SPACs) ,
Stock Redemption ,
U.S. Treasury
Following the enactment of the Inflation Reduction Act (IRA) on August 16, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) recently issued six notices (the “Notices”) requesting comments on...more
Knowing who owns legal entities is essential to stopping terrorism, money laundering, and other sophisticated criminal enterprises. For entities formed in the United States there has never been a requirement to disclose...more
10/12/2022
/ Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Disclosure Requirements ,
Final Rules ,
FinCEN ,
IRS ,
Money Laundering ,
New Regulations ,
Ownership Interest ,
Penalties ,
Taxpayer Identification Number
The US Internal Revenue Service (IRS) recently released Notice 2022-36, in which the IRS announced that it is automatically waiving (and automatically abating, refunding, or crediting, as appropriate) penalties for failure to...more
Projects that produce or recycle wind turbine blades, manufacture energy storage equipment, or refine or blend renewable or low-carbon fuels may qualify for up to a 30 percent tax credit under the Inflation Reduction Act...more
This week, President Biden signed legislation designed to infuse billions of dollars into the economy to promote clean energy, manufacturing, and construction through a wide array of tax incentives and grants. ...more
Today, President Joe Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). Although the proposal further restricting the availability of long-term capital gain treatment with respect to carried interests...more
The Inflation Reduction Act of 2022 (IRA), has several primary goals, including: promoting clean energy, manufacturing, and construction through a wide array of tax incentives and grants; raising revenue through the primary...more