This Memorandum continues our analysis of the current U.S. federal tax reform process. Today, the House of Representative passed the Senate’s version of the One Big, Beautiful Bill (the “Senate Tax Bill”). The Senate Tax Bill...more
The effective dates of the Department of Labor’s new 2024 fiduciary advice rule (the “2024 Fiduciary Rule”) and the amendments to Prohibited Transaction Exemptions 84-24, 75-1, 77-4, 80-83, 83-1, 86-128, and 2020-02 (the...more
The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more
Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more
On April 25, 2024, the U.S. Department of Labor (the “DOL”) finalized a collection of regulatory changes in its ongoing quest to update the definition of a “fiduciary” under ERISA and Section 4975 of the Internal Revenue Code...more
5/17/2024
/ 401k ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary Duty ,
Individual Retirement Account (IRA) ,
Internal Revenue Code (IRC) ,
Investors ,
Policies and Procedures ,
Private Funds ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
On April 3, 2024, the U.S. Department of Labor (DOL) published significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The amendment becomes effective on June 17, 2024; however, certain...more
4/9/2024
/ Compliance ,
Criminal Convictions ,
Deferred Prosecution Agreements ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Exemptions ,
Financial Crimes ,
Investment Management ,
New Amendments ,
Non-Prosecution Agreements ,
Notice Requirements ,
Prohibited Transactions ,
QPAM ,
Shareholders
On January 24, 2024, the U.S. Department of Labor (DOL) published the final rule amending the procedures for filing an individual prohibited transaction exemption application. The amended regulation (the “Procedures”)...more