The Internal Revenue Service (the “Service”) is considering requiring businesses to report “uncertain tax positions” if they are “a business taxpayer with total assets in excess of $10 million…. [or] a taxpayer who prepares financial statements, or is included in the financial statements of a related entity, so long as that taxpayer or related [...]
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Taxation of Carried Interest – The Debate Continues as Legislation Looms
0 Comments | Posted by Administrator in Uncategorized
I first wrote about proposed changes in the taxation of carried interests (the manager’s share of income from a venture or private equity fund) in June of 2008 (see http://archive.constantcontact.com/fs056/1101631528224/archive/1102150842963.html). Last December, the House finally approved a bill to tax carried interests at ordinary income rates rather than capital gains rates (and subject such [...]
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COBRA Premium Subsidy Eligibility Period Extended
0 Comments | Posted by Administrator in Uncategorized
As discussed in a recent post regarding the government’s COBRA program, the American Recovery and Reinvestment Act of 2009 made certain individuals terminated in the period beginning Sept. 1, 2008 and ending December 31, 2009 eligible to receive a government financed subsidy equal to 65% of the COBRA continuation premium. Such program was initiated in [...]
The Obama administration has just made my year-end busier. On November 7th, the President signed into law the Worker, Homeowner, and Business Act of 2009 (the “WHB 2009 Act”) which, among other things, extends the period that businesses can carry back a net operating loss (NOL) arising in either 2008 or 2009. This [...]
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The Entertainment Industry and § 409A: That’s Hollywood!
0 Comments | Posted by Administrator in Uncategorized
By now, everyone has heard of Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”), which has turned traditional deferred compensation on its head by including deferrals in gross income unless they meet strict requirements. While Hollywood may have been the furthest thing from Congress’s collective mind when Code Section 409A [...]
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Offshore Bank Account Reporting Developments
1 Comment | Posted by Administrator in Uncategorized
In an act of charity, or good business (depending how you look at it), the IRS announced an extension, through October 15, 2009, of the deadline to participate in the foreign bank account voluntary disclosure program. The program, unveiled March 26, 2009, provides penalty relief for individuals that have failed to adequately report income tied [...]
