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Searching Content by Roger J. Baneman ordered by Published Date Descending.
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Tax Court Rules Family Office Is Engaged In A Trade Or Business
On December 13, 2017, in Lender Management, LLC v. Commissioner, the U.S. Tax Court ruled that a family office, Lender Management, LLC ("Lender Management"), was "carrying on a trade or business"...
United States
15 Jan 2018
2
New Partnership Audit Procedures May Dramatically Affect The Assessment And Collection Of Taxes Relating To Partnership Activities
The Bipartisan Budget Act of 2015 (the "BBA"), which was signed into law in November 2015, includes sweeping changes to the rules governing federal tax audits of entities treated as partnerships...
United States
3 Feb 2016
3
Final Regulations Under Section 871(m) Clarify Withholding Tax Rules For Equity-Linked Derivatives, Yet Many Challenges Remain
On September 17, 2015, the Treasury Department and the Internal Revenue Service (the "IRS") issued new temporary and final regulations under section 871(m) of the Internal Revenue Code...
United States
20 Oct 2015
4
United States And Brazil Sign FATCA Intergovernmental Agreement
The United States and Brazil have signed a "Model 1" intergovernmental agreement ("IGA") with respect to the US Foreign Account Tax Compliance Act.
United States
11 Oct 2014
5
Treasury And IRS Issue Inversion Notice
The Treasury Department and the IRS released Notice 2014-52 on September 22nd to limit expatriation transactions.
United States
6 Oct 2014
6
FATCA: Implications For Non-US Funds
FATCA refers to the US Foreign Account Tax Compliance Act (contained in Sections 1471 through 1474 of the US Internal Revenue Code).
United States
2 Jun 2014
7
United States Signs FATCA Intergovernmental Agreement With The Cayman Islands
The US Department of the Treasury recently announced that the United States has signed a "Model 1" intergovernmental agreement with respect to the US Foreign Account Tax Compliance Act ("FATCA") with the Cayman Islands.
United States
16 Dec 2013
8
New Proposed Regulations Under Section 871(m) Adopt A Single Factor Test But Delay Effective Date Until 2016
On December 4, 2013, the Treasury Department and the Internal Revenue Service released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal withholding tax on certain equity-linked payments.
United States
13 Dec 2013
9
Revival Of REIT Rulings Could Mean Good News For Companies With Non-Traditional Assets Considering Becoming Reits
In recent years, there has been a considerable expansion of the types of companies holding non-traditional real estate assets that have elected to become real estate investment trusts for US federal income tax purposes ("REITs").
United States
27 Nov 2013
10
Timeline For Initial FATCA Implementation Extended
The Treasury Department and the Internal Revenue Service announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act or FATCA from January 1, 2014 to July 1, 2014.
United States
16 Jul 2013
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