- The IRS Large Business and International Division recently issued a memorandum providing that it will not challenge a taxpayer's application of this success-based fee safe harbor to certain milestone payments so long as specific criteria are met.
- When unexpected disputes arise on critical projects, concerns about schedule, completion costs and the administrative burden of resolving the dispute soon follow.
- Updates for hedge and PE funds including the Sun Capital decision, new temporary identified mixed straddle regulations, and FATCA.
- The US Department of Labor (DOL) provides the Voluntary Fiduciary Correction Program (VFCP) for benefit plan sponsors that need to correct various violations of the Employee Retirement Income Security Act of 1974 (ERISA). Some examples include failing to timely remit participant contributions and loan repayments to the plan, and making below market interest rate loans with parties in interest.
- The newest revision to the Insurance Holding Company System Model Regulation (the Act) has added the annual filing requirement of Form F - Enterprise Risk Reporting. Form F focuses on risk created by non-regulated entities, while ORSA primarily focuses on regulated entity risk.
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