- Many tax-exempt organizations and employee benefit plans, such as pensions, IRAs and retirement plans, are attracted to hedge or private equity funds (Funds) as a method of realizing above-average returns on investments. Since related function or passive income is exempt from federal income tax, and many hedge or private equity investments are passive to the tax-exempt, most income generated from these entities can be generated free of federal and state income tax.
- Changes to the IRS offshore voluntary compliance programs expands reach as well as opportunities for nonwillful disclosure of offshore assets.
- On July 21, 2014, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter FIL-40-2014. The guidance clarifies how the FDIC will evaluate requests by S-Corporation banks to make shareholder dividend payments to cover taxes on their pass-through share of the bank's earnings. Without FDIC approval, these dividends would not be permitted under the capital conservation buffer requirements in the Basel III rule.
- On May 9, 2014, the IRS Office of Chief Counsel issued a memorandum discussing the tax treatment for payments that auto dealerships receive from manufacturers from facility image upgrade programs.
- As a result of additional regulatory requirements, merger and acquisition discussions and activity are increasing in the banking industry. Associated transaction costs incurred related to a merger or acquisition transaction can be significant. These costs can include fees for financial advice, legal services, due diligence services, and expenses to arrange debt financing and can greatly impact a company’s financial statement.
- Previous Next