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IRS memorandum finds loans to U.S. borrowers by foreign lender with U.S. agent are subject to U.S. taxation

Katten Muchin Rosenman LLP
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USA
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September 24 2009

The Associate Chief Counsel (International) of the IRS has issued a memorandum in which it concludes that a foreign corporation (“LoanCo”) is engaged in a U.S. trade or business and subject to U.S. taxation on its net income from loans made by LoanCo to U.S. borrowers under the following circumstances

Illinois passes state QTIP legislation does your estate plan need to be updated to take advantage?

Katten Muchin Rosenman LLP
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USA
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September 28 2009

Illinois Governor Patrick Quinn signed into law Illinois SB 2115 as Public Act 96-789 on September 8, 2009

California Franchise Tax Board requests additional information for refund claims by foreign limited liability companies having no income from California

Katten Muchin Rosenman LLP
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USA
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April 18 2008

On April 14, the California Franchise Tax Board (FTB) issued Notice 2008-2 to inform limited liability companies that filed protective claims for refunds in connection with the court ruling in Energetic Services, LLC v. Franchise Tax (Northwest) that additional information is required to determine if their circumstances mirror those in Northwest so that their claims for refunds may be processed

Tax payers entitled to compound interest when tax paid in error

Katten Muchin Rosenman LLP
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United Kingdom
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August 10 2007

In a landmark judgment handed down by the UK’s highest appeal court, the House of Lords, on July 18 (published on August 6), held that compound interest is recoverable in claims for restitution

Legislation regarding publicly traded partnerships

Katten Muchin Rosenman LLP
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USA
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June 22 2007

U.S. Senators Baucus and Grassley have introduced a bill aimed at taxing as corporations partnerships that make their interests available on an exchange or market and that earn income from investment adviser and related asset management services

Bill introduced that would tax “performance allocations” as ordinary income

Katten Muchin Rosenman LLP
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USA
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June 29 2007

On June 22, a bill was introduced in the House of Representative that would amend the Internal Revenue Code of 1986 to tax as ordinary income the “performance allocation” or “carried interest” received by a partner that provides advisory services to the partnership

IRS announces one-time extension for voluntary disclosure

Katten Muchin Rosenman LLP
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USA
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September 21 2009

Today, September 21, 2009, the IRS extended the deadline for the special voluntary disclosures by taxpayers with unreported income from offshore accounts to October 15, 2009

IRS and Treasury issue guidance for modification of securitized commercial mortgages

Katten Muchin Rosenman LLP
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USA
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September 22 2009

In recent years, a significant portion of all commercial mortgage loans have been securitized, and now are held by trusts characterized as real estate mortgage investment conduits (REMICs) for federal income tax purposes

IRS eases rules on modification of securitized commercial mortgage loans

Katten Muchin Rosenman LLP
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USA
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September 18 2009

On September 15, the Internal Revenue Service published Revenue Procedure 2009-45 providing that a servicer may agree to a substantial modification of any commercial mortgage loan as long as the servicer reasonably believes that there is a significant risk of default of the pre-modification loan upon maturity of the loan or at an earlier date, without thereby causing the real estate mortgage investment conduit (REMIC) or grantor trust status of a securitization vehicle to be challenged

FASB denies request to delay implementation of FIN 48

Katten Muchin Rosenman LLP
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USA
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January 19 2007

On January 17, the Financial Accounting Standards Board voted unanimously not to delay the effective date of FASB Interpretation No. 48 Accounting for Uncertainty in Income Taxes (FIN 48

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Search results

IRS memorandum finds loans to U.S. borrowers by foreign lender with U.S. agent are subject to U.S. taxation

Illinois passes state QTIP legislation does your estate plan need to be updated to take advantage?

California Franchise Tax Board requests additional information for refund claims by foreign limited liability companies having no income from California

Tax payers entitled to compound interest when tax paid in error

Legislation regarding publicly traded partnerships

Bill introduced that would tax “performance allocations” as ordinary income

IRS announces one-time extension for voluntary disclosure

IRS and Treasury issue guidance for modification of securitized commercial mortgages

IRS eases rules on modification of securitized commercial mortgage loans

FASB denies request to delay implementation of FIN 48

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