Public Beneficial Ownership Disclosure Under N.Y. LLC Transparency Act
Introduction. On January 9, 2023, New York State (“State”) Senate introduced the New York LLC Transparency Act, S. 995-B (the “Act”)
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MARINA VISHNEPOLSKAYA, ESQ., P.C.
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Jan 12, 2023
Final FinCEN Beneficial Ownership Reporting Rules Pose Compliance Issues for LLCs
On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of Treasury...
Sep 13, 2021
Corporate Tax Proposals in House Ways and Means Committee Summary
Introduction; Summary of Proposed Tax Reforms. On September 13, 2021, the Ways and Means Committee of the United States House of...
Aug 11, 2021
FinCEN Compliance with Corporate Transparency Act of 2020
Introduction. On January 1, 2021, the Corporate Transparency Act of 2020 (“CTA”) was enacted into law as part of H.R. 6395, the National...
Aug 2, 2021
Update - Suspension of IRS Form 990 Schedule B Disclosure Rules by NYS AG
On July 29, 2021, the Office of the New York State (NYS) Attorney General (AG), Charities Bureau announced suspension of the IRS Form 990...
Jul 29, 2021
U.S.-Swiss Tax Treaty Benefits for Dividend Payments to IRAs Under the 2021 CAA
Introduction. On June 7, 2021, the IRS published in Announcement 2021-11, 2021-23 I.R.B. 1196 the new Competent Authority Arrangement...
Apr 8, 2021
IRS Confirms Temporary Full Deduction for Employee Virtual Business Meals
On April 8, 2021, the IRS issued Notice 2021-25 (the "Notice") confirming availability of a temporary 100-percent deduction under section...
Jan 6, 2021
Compliance Items for Foreign Investors Under the Corporate Transparency Act of 2020
Introduction. On January 1, 2021, the United States Senate passed H.R. 6395, the National Defense Authorization Act, 2021 (“NDAA”) over...
Aug 24, 2020
Excluding High-Taxed Foreign Income Under Final GILTI HTE Regulations and Proposed Section 954(b)(4)
Background On July 20, 2020, Treasury and the IRS issued proposed regulations (“Proposed Regulations”) under section (“Section”)...
Aug 4, 2020
Overview of Proposed Carried Interest Regulations Under Code Section 1061
Background On July 31, 2020, Treasury and the IRS issued proposed regulations, REG-107213-18 ("Proposed Regulations") under section...
Jul 12, 2020
Extension of PPP, Discontinued EIDL Advances Offer Limited Tax Planning Opportunities
On July 4, 2020, legislation introduced in the Senate on June 30, 2020, initially the last date for submitting an application under the...
Jun 28, 2020
PPP Flexibility Act Approaches Tax Parity Between Loan Forgiveness and Employee Retention Credits
Section 1102 of the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136 (2020) (CARES Act) sets forth requirements...
May 19, 2020
SBA Clarifies Inclusion of Foreign Affiliates in Employee Limit for PPP Loan Eligibility
Employees of foreign affiliate of a small business based in the United States count toward the 500-employee limit under SBA guidance...
May 6, 2020
Tax Credits and PPP Loans for Eligible Employer Payroll Costs
On May 5, 2020, three senators who are leaders of their respective congressional tax-writing committees asked Treasury in a letter to...
Mar 30, 2020
IRS Notice 2020-21 Confirms Effective Date of H.R. 6201 Payroll Tax Credit
H.R. 6201, the Families First Coronavirus Response Act ("Act"), signed by President Trump into law on March 18, 2020, generally provides...
Mar 25, 2020
I.R. 2020-58 and I.R. 2020-59 Announce Extended IRS Filing Deadline and Suspend IRS Enforcement
The IRS deferred the federal income tax filing deadline of April 15, 2020 for all taxpayers because of the coronavirus in Notice 2020-18...
Dec 31, 2019
LLCs As Private Equity Fund Acquisition Vehicles for Portfolio Companies With Multiemployer Pension
On November 22, 2019, the First Circuit Court of Appeals decided Sun Capital Partners III, LP v. New England Teamsters & Trucking...
Dec 12, 2019
Incentives for Emerging Growth Companies to Revoke S Election
The Firm's article, "Incentives for Emerging Growth Companies to Revoke S Election", is forthcoming in next week's issue of Bloomberg Tax...
Nov 19, 2019
Journal of Corporate Taxation Article,
"Reporting Transfers of Partnership Interests Subject to Section 1446(f)" The Firm's article, "Reporting Transfers of Partnership...
Oct 29, 2019
H.R. 2513, Corporate Transparency Act of 2019
Introduction. On October 22, 2019, the United States House of Representatives passed H.R. 2513, titled, Corporate Transparency Act of...
Apr 4, 2017
IRS Form 5472 Requirements for Disregarded LLCs Wholly Owned by Foreign Exempts
Background: Foreign, Domesticated SMLLCs. Foreign charitable organizations and pension funds (hereafter, “exempts” due to their...
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