Tax & Benefits Blog

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Jul 11, 2023

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”)

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...

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...

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...

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”)...

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...

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...

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...

Oct 3, 2019

Coordination With FIRPTA on Sale of Partnership Interests Under Proposed Section 1446(f) Regulations

Treasury and the IRS published proposed regulations, 84 Fed. Reg. 21,198 (May 13, 2019) (the “Proposed Regulations”) for withholding 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...

MARINA VISHNEPOLSKAYA, ESQ., P.C. Providing sophisticated legal solutions to address your corporate and tax business needs.

Tax & Benefits Blog

MARINA VISHNEPOLSKAYA, ESQ., P.C.

Providing sophisticated legal solutions
to address your corporate and tax
business needs.