Brass Tax

IRS Eliminates TIN Disclosure Requirement for Partnership Representatives and Designated Individuals

The IRS no longer requires partnership representatives or designated individuals to share their TINs on partnership or REMIC tax returns.

Escape from New York? Not So Fast

The New York City Tax Appeals Tribunal recently held that an out-of-state corporate investor in a master fund was subject to New York corporate tax on its share of capital gain from the master fund’s sale of an interest in a limited liability company that was engaged in business in New York.

U.S. individual shareholders of a CFC are eligible to make a Section 962 election to be taxed as if they held the CFC through a U.S. corporation. Recently issued proposed regulations provide that the hypothetical U.S. corporation may be eligible for a 50 percent deduction on its GILTI as if were an actual U.S. corporation.

Tax laws in many jurisdictions, including the United Kingdom, are – to varying degrees – based on accounting standards. The interaction between tax accounting and financial accounting almost inevitably raises a number of questions, such as why is there a difference, what precisely are the differences and whether (let alone can!) these differences can be reconciled.

On March 18, 2019, the Department of Treasury confirmed that RICs wishing to invest in commodity-linked notes are, at best, on their own.

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