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Bipartisan Proposal Attempts to Provide Solutions for Comprehensive Regulation of Digital Assets

On June 7, 2022, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced the Responsible Financial Innovation Act (RFIA), a bipartisan effort to develop and provide greater regulatory clarity to the eclectic...more

Filing Deadline Extended for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2018 to file the Report of Foreign Bank and Financial Accounts....more

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

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

IRS Announces Fines Paid to FINRA Are Not Deductible

Fines pertaining to violations of federal securities laws and certain FINRA rules may not be deducted. The Internal Revenue Service (IRS) in low-level advice recently announced its position that certain fines paid to...more

FinCEN Extends Filing Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2017 to file the Report of Foreign Bank and Financial Accounts....more

IRS Offers Tax Guidance Relating to Money Market Fund Rules

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

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs. On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more

FinCEN Again Extends Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more

FinCEN Announces Third Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

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