Private Equity (PE) and Venture Capital (VC) funds often attract significant investment from US tax-exempt entities.  In doing so, these funds may need to avoid having Unrelated Business Taxable Income (UBTI).  This article will address some of the scenarios that can cause a fund to generate UBTI. US tax-exempt entities such as qualified pension funds, […]

Can a US person who owns shares in a foreign corporation be subject to current taxation on the undistributed earnings and profits of that foreign corporation? The short answer to that question is that it is possible but as with everything US tax related, the answer depends on the facts and circumstances of each case. […]

Last month, the Internal Revenue Service (IRS) finalized proposed regulations on the designation and authority of a partnership representative under the centralized partnership audit procedures that went into effect for tax years after December 31, 2017. This article addresses some of the key points of the final regulations. Prior to discussing these regulations, we thought it […]

On December 20, 2017, Congress passed H.R. 1 – the Tax Cuts and Jobs Act (TCJA) – providing for the largest changes to the US tax code since 1986 and President Trump signed the bill into law on December 22, 2017. As we have done previously, we have highlighted the changes made to US Federal […]

This past weekend, the US Senate passed H.R. 1 – the Tax Cuts and Jobs Act – providing for the largest changes to the US tax code since 1986. The following is a list of “highlights” in the legislation (along with differences from the House bill passed on November 16, 2017): Corporate Tax Provisions Much like […]

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released their initial attempt at tax reform. The document is entitled “Unified Framework for Fixing Our Broken Tax Code.” Some of the highlight items include: Consolidating the current seven income tax brackets into three brackets […]

PLEASE NOTE: For new rules concerning single member foreign owned LLC’s please also read our post  New IRS Reporting Requirements Foreign-owned US LLCs. With the passage and implementation of the Foreign Account and Tax Compliance Act (FATCA), much has been made of the US government’s attempt to crack down on its citizens’ use of accounts […]