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Five Excise Tax Tips For Tax-Exempt Employers

USA - March 12 2019 As we have previously discussed, the 2017 tax reform act created a new excise tax under section 4960 of the Internal Revenue Code that will affect...


“Passthrough Deduction” Regulations Finalized

USA - March 11 2019 On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final...

David S. Miller, Jo Habenicht, Mitchell M Gaswirth, Richard M Corn, Michael Fernhoff.


Extension of FBAR Filing Deadline for Certain Filers

USA - February 11 2019 On December 4, 2018, FinCEN issued Notice 2018-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form...

David S. Miller, Martine Seiden Agatston, Michael Fernhoff, Abraham Gutwein.


Proposed Rental Business Safe Harbor under Section 199A

USA - February 7 2019 On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the...

David S. Miller, Elizabeth Johnston Wytock, Stuart L Rosow, Richard M Corn, Michael Fernhoff, Timothy W. Donovan.


Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)

USA, OECD - January 25 2019 On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid”...

David S. Miller, Sean M. Webb, Stuart L Rosow, Martin T Hamilton, Michael Fernhoff.