As we have previously discussed, the CARES Act created the Paycheck Protection Program, pursuant to which employers may be able to obtain loans (“PPP loans”) to help cover business expenses during the COVID-19 pandemic. Under...more
On April 10, 2020, the Internal Revenue Service (“IRS”) released frequently asked questions (FAQs) to address specific issues relating to the deferral of the employer portion of Social Security taxes under the Coronavirus...more
On March 30th, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report which concluded, based on its estimates, that the IRS could have collected significant additional tax revenue from cannabis...more
The IRS and Treasury issued new guidance that supersedes earlier guidance relating to the postponement of the April 15, 2020 tax deadline due to the COVID-19 pandemic.
On Friday, the IRS and Treasury announced that both the...more
Now that the devastating scope of the COVID-19 pandemic has become clear, the United States government is responding rapidly to address both its health care and economic impacts. Two emergency supplemental appropriations...more
3/23/2020
/ Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Families First Coronavirus Response Act (FFCRA) ,
IRS ,
New Legislation ,
Paid Leave ,
Relief Measures ,
Sick Leave ,
Tax Credits ,
U.S. Treasury
Due to the COVID-19 pandemic, the Treasury has announced that the due date for any U.S. federal income tax payments otherwise due on April 15th has been extended to July 15th, subject to certain limitations. This extension of...more
Highlights:
..Unless Congress acts in the next three weeks, effective as of January 1, 2020, a 2.3% excise tax (the “Medical Device Tax”) generally will be imposed on the price at which a “taxable medical device” is sold...more
Every U.S. person (including both individuals and entities, as discussed below) that had a financial interest in, or signature or other authority over, one or more foreign financial accounts during 2015 must electronically...more
The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more
The Internal Revenue Service has issued a private letter ruling to an individual owner of solar panels installed in an offsite net-metered community-shared solar project confirming the individual’s eligibility for the income...more
On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more
7/31/2015
/ Capital Gains ,
Clawbacks ,
Deferred Compensation ,
Fee Waivers ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits Interests ,
Significant Entrepreneurial Risk (SER)
Don’t Forget About Your Foreign Financial Assets -
U.S. citizens, resident aliens and certain non-resident aliens who held any interest in “specified foreign financial assets” at any point during 2014 may be required...more
On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more
On August 19, 2013, the IRS began to accept applications for registration under FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, by requiring foreign financial institutions (“FFIs”),...more
On July 12, 2013, the IRS issued new guidance regarding FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers. In particular, the IRS (1) revised certain elements of the timeline for FATCA...more
Offshore Master with U.S. and Offshore Feeders -
This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more
Reports Due Before the End of June -
Every U.S. person that had a financial interest in, or signature authority over, a foreign financial account during 2012 must file U.S. Treasury Form TD F 90-22.1, Report of Foreign...more
Earlier this year, the IRS announced that U.S. entities that hold interests in “specified foreign financial assets” will not be required to report such interests on IRS Form 8938 until final regulations are issued, and in no...more
U.S. Funds with Only U.S. Investors -
FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more