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Congress targets partnerships: new partnership tax audit rules

USA - November 2 2015 On November 2, 2015, the Bipartisan Budget Act of 2015, (the Budget Act) was enacted, which contains new rules for partnership tax audits. The Budget…

Christian Brause, Timothy J. Devetski, Bridget R. O’Neill

IRS issues final regulations on dividend equivalents under Section 871(m)

USA - September 18 2015 On September 17, 2015, the Treasury Department and the Internal Revenue Service (IRS) released final, temporary and proposed regulations (the Final…

Timothy J. Manion

President’s Budget Proposes to Eliminate Tax Gap

USA - February 15 2016 On February 9, 2016, the White House released President Obama's fiscal 2017 budget, which proposes to eliminate the statutory gap that currently…

Bridget R. O’Neill, Joseph M. Paral

Harsh withholding, carried interest rules offset cost of extenders

USA - December 9 2009 On December 7, 2009, Charles Rangel, chair of the House Ways and Means Committee, introduced the "Tax Extenders Act of 2009," which extends for one year certain provisions scheduled to expire at the end of 2009 and offsets the cost of the extensions with revenue from provisions that, in general, would tax partnership income from investment management services at ordinary income rates and would impose a 30% withholding tax on payments to foreign financial institutions that fail to comply with certain reporting obligations.

Laura M. Barzilai, Nicholas R. Brown, Robert M. Kreitman, Bridget R. O’Neill, Sharp Sorenson

Term Asset-Backed Securities Loan Facility update

USA - March 5 2009 On March 3, 2009, the Federal Reserve Board released the final terms and conditions applicable to the initial loan subscription, including loan rates and collateral haircuts, relating to its previously announced Term Asset-Backed Securities Loan Facility (TALF).

R.J. Carlson, Mark J. Kowal, Daniel M. Rossner