March 21, 2019

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

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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.

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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.

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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.

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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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