April 2014

FATCA – The Time is Now: IRS Provides Limited Relief for Some Foreign Financial Institutions, But Many Will Need to Register by May 5

The Foreign Account Tax Compliance Act (FATCA) was enacted as a component of the HIRE Act of 2010. Among other things, FATCA imposed a new 30% withholding tax with respect to certain payments made to any foreign financial institution (FFI), including a for…

2013 Developments in U.S. International Tax

U.S. international tax is a constantly evolving field, and this was certainly true in 2013.  This article highlights several of the developments during the past year.

October 2013

Section 1202: Opportunity for Tax Savings upon the Sale of Small Business Stock

Small business owners often shun C Corporation status because of its various tax drawbacks, perhaps most significantly, the dreaded double tax.  However, in recent years, Congress has enacted tax provisions designed to incentivize new investment in small …

February 2013

Tax-Exempt Checkup

The 501(c)(3) tax-exempt status of a non-profit is conditioned on many requirements and restrictions. The following list summarizes some of the items that such an organization must keep in mind in its day-to-day operations and may serve as a convenient che…

January 2013

Tax-Exempt Issuers and Borrowers Need Written Post-Issuance Compliance Policies

ARE YOU A NON-PROFIT OR GOVERNMENTAL ENTITY WITH OUTSTANDING TAX-EXEMPT BONDS? ARE YOU CONSIDERING FINANCING A PROJECT WITH TAX-EXEMPT BONDS? IF SO, YOU SHOULD HAVE A WRITTEN “POST-ISSUANCE COMPLIANCE POLICY” IN PLACE.The status of an issuer or borrowe…

Tax Exempt Borrowing Basics – A Quick Reference Guide to Tax-Exempt Bonds

Tax-exempt debt provides a valuable financing option for governmental and tax-exempt entities, but typically involves complicated, precise structures and language. Below is a general reference guide for those new to tax-exempt bonds.Who can borrow using …