On August 25th, 2021, The New York State Department of Taxation and Finance published TSB-M-21(1)C, providing guidance on the pass-through entity tax (NY PTET). As stated in our article back in April 2021, the New York passthrough entity tax was enacted as a SALT workaround for individual taxpayers to combat the $10,000 itemized deduction limitation. […]
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California is one of the latest of several states to enact a state and local tax (SALT) cap workaround by instituting an elective pass-through entity (PTE) tax to provide business owners with some relief from the $10,000 Federal cap on SALT deductions. In guidance issued last November, the IRS consented to this technique, which allow […]
On March 20, 2020, the IRS issued Notice 2020-18 detailing specifics of the Federal tax filing and payment extensions that came about as a result of the COVID-19 pandemic. Although many of the associated deadlines were moved to align with the new July 15th filing and payment deadlines, there are a few notable exceptions to […]
When gearing up for year-end business tax planning, there are many tax provisions for businesses that were included in the Tax Cuts and Jobs Act (TCJA) which can help you reduce your federal tax liability and maximize your tax savings opportunities. Particular items to watch for when you’re thinking about your year-end business tax planning […]
Recently, the IRS and the U.S. Treasury Department held a public hearing on proposed regulations that would dramatically alter the treatment of related-party indebtedness for federal income tax purposes. The proposed regulations, issued under Internal Revenue Code Sec. 385, were designed to inhibit corporate inversions and cross-border “earnings stripping” strategies. But critics argue that they go […]
A Collateralized Debt Obligation (CDO) can offer attractive returns, but they’re also subject to complex accounting, tax implications, and regulatory requirements. As an investor, here are some things you should consider. Collateralized Debt Obligation Defined A CDO is a financial tool used to re-package loans into a product sold to investors in the secondary market […]
If you trade futures, options, or similar investments, it’s important to familiarize yourself with Internal Revenue Code Sec. 1256. That section offers lower capital gains tax rates for shortterm trading of regulated futures contracts, foreign currency contracts, non-equity options (including broad-based stock index options), dealer equity options and dealer securities futures contracts (collectively, “Sec. 1256 […]
When it comes to hedge fund cybersecurity they can’t afford to take a reactive approach. Data breaches and frauds at financial institutions, investment firms and other financial services providers continue to make headlines at unprecedented rates. So all funds should have a plan for addressing cyber risks. Understand the Problem In April 2014, the SEC’s […]
Earlier this year, the SEC issued welcome guidance on the prohibition against investment advisor advertising in testimonials and its implications for social media websites. In Guidance Update 2014-4, the SEC’s Division of Investment Management clarified that Registered Investment Advisors are allowed to publish third-party reviews — from sites such as Yelp or Angie’s List — […]
On December 30, 2013, the U.S. Treasury Department and the IRS issued regulations which defines a Passive Foreign Investment Company shareholder (PFIC) and outline the reporting requirements for PFICs. These rules are effective for tax years ending after December 30, 2013. What Constitutes a Passive Foreign Investment Company Shareholder? A Passive Foreign Investment Company shareholder is […]