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...
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MARINA VISHNEPOLSKAYA, ESQ., P.C.
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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 12, 2021
Schedule B Contributor Disclosure by Charities After Americans for Prosperity Foundation v. Bonta
Introduction. After more than a decade of litigation, the California Attorney General's ("AG’s") IRS Form 990, Schedule B disclosure...
Jun 7, 2021
COBRA Premium Assistance Requirements for Exempt Employers
On April 7, 2021, the United States Department of Labor (“DOL”) issued guidance interpreting the premium assistance requirements for...
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...
Sep 3, 2020
Payroll Tax Deferral Under Notice 2020-65, FFCRA and CARES Act
Introduction On August 8, 2020, the President of the United States issued an executive order, 85 Fed. Reg. 49,857 (Aug. 13, 2020)...
Jul 26, 2020
Covid-19 Leave-Based Donation Program Necessitates Strict Compliance With Safe Harbor
On June 11, 2020, the IRS issued Notice 2020-46 (the “Notice”) permitting employers to claim a charitable contribution deduction under...
Apr 21, 2020
Bill Passed by Senate Provides Further Allocations for PPP Loans
Today, the Senate passed the bill, Paycheck Protection Program and Health Care Enhancement Act (“PPP and HCE Act”), which provides...
Apr 5, 2020
Federal Paid Leave Tax Credits for Religious Employees Affected by Coronavirus
Paid Leave requirements and tax credits under the Families First Coronavirus Response Act (the "Act"), as amended by the CARES Act, apply...
Mar 31, 2020
IRS Notice 2020-22 Offers Guidance on Retaining Withheld Taxes
IRS Notice 2020-22, issued on March 31, 2020, offers guidance with respect to the payroll credits under the Families First Coronavirus...
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...
Oct 17, 2019
Key Remedial Amendment Due Dates for Individually Designed 403(b) Plans Under Rev. Proc. 2019-39
Introduction. In Revenue Procedure 2019-39, effective September 30, 2019, Treasury and the IRS designated recurring remedial amendment...
Feb 28, 2019
Private Letter Ruling 201904008 Cautions on Nonprofit Compensation for Religious Duties
In Private Letter Ruling 201904008 (Oct. 29, 2018), published on January 25, 2019 (the “Ruling”), the Internal Revenue Service (“IRS”)...
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...
Feb 28, 2017
Correcting Nonqualified Deferred Compensation Plans Under Recently Proposed Regulations
Proposed Section 409A Regulations. Marina's article, "Correcting Document Failures of Plans With Nonvested Deferred Compensation Under...
Apr 7, 2015
Recent IRS Rulings Remind Charities to Avoid Grants to Pre-Selected Individuals
Recent IRS Rulings Finding Prohibited Private Benefit to Pre-Selected Individuals. The IRS issued recently several private letter...
Nov 25, 2014
Recent IRS Ruling Illuminates Procedures for Grants to Foreign Charities
On September 19, 2014, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 201438032 (I.R.S. Priv. Ltr. Rul....
May 15, 2014
May Employers Use an Involuntary Separation From Service Without Cause as an SRF?
Background. Internal Revenue Code section (“Section") 83 provides rules for timing of inclusion in income of compensation consisting of...
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