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Results: 1-10 of 35

Significant tax provisions of the American Recovery and Reinvestment Act of 2009

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • February 25 2009

On Feb. 17, 2009, President Obama signed into law the American Recovery and Reinvestment Act of 2009

Legislation introduced to tax incentive-based allocations as ordinary income

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • June 26 2007

Legislation has been introduced in the House of Representatives, H.R. 2834, which, if enacted, would generally treat incentive allocations (often referred to as “carried interests”) by investment partnerships as ordinary income for the performance of services, which would be subject to ordinary income rates and, in the case of many individuals, self-employment taxes

FIRPTA a tax trap for the unwary activist fund manager

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • July 12 2007

It is common knowledge that foreign investors who invest in U.S. publicly traded equities are exempt from tax on their capital gains

New legislation limiting deferral of offshore compensation proposed; side pocket incentive fees may be significantly impacted

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • May 20 2008

On May 15, 2008, the House Ways and Means Committee approved for inclusion in the “Energy and Tax Extenders Act of 2008” (H.R. 6049) new limitations on the ability of a cash-basis taxpayer to defer compensation earned from many non-U.S. corporations (including offshore hedge funds) and certain partnerships not comprised primarily of taxable U.S. persons (“nonqualified entities”

Amendments to Brownfield Cleanup Program alter tax credits but not eligibility criteria

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • August 7 2008

On June 23rd, Governor David A. Paterson signed into law amendments to New York’s Brownfield Cleanup Program (BCP

IRS issues additional guidance on COBRA premium subsidy

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • April 10 2009

As we previously reported in "New Stimulus Package Creates Subsidy for Health Care Continuation Coverage" (SRZ Alert, March 9, 2009) and "Department of Labor Issues Model Notices for Subsidized COBRA Premiums"(SRZ Alert, March 20, 2008), the American Recovery and Reinvestment Act of 2009 (the "ARRA") expands the rights of assistance eligible individuals under the Consolidated Omnibus Budget and Reconciliation Act of 1985, as amended ("COBRA"), by subsidizing 65 percent of their COBRA premiums

Deadline for complying with the final Section 409A regulations governing deferred compensation arrangements is Dec. 31, 2008

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • August 28 2008

Section 409A of the Internal Code of 1986, as amended (“Section 409A”), impacts many common forms of compensation deferred by certain cash-basis taxpayers after 2004 or, in certain circumstances, earlier

Tax legislation limits future deferrals, penalizes future side pocket incentive fees from offshore funds

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • October 7 2008

On Oct. 3, 2008, the Emergency Economic Stabilization Act of 2008 (H.R. 1424) was signed into law

Impact of IRC Section 457A on fund structures

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • October 22 2008

As you are aware, on Oct. 3, 2008, the Emergency Economic Stabilization Act of 2008 (H.R. 1424) was signed into law

2009 dollar limits for retirement plans

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • October 21 2008

On Oct. 16, 2008, the Internal Revenue Service and the Social Security Administration issued the inflation-adjusted amounts that will affect qualified retirement plans and Social Security benefits effective Jan. 1, 2009

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