In general, Section 1061 requires a three-year holding period for an investment fund manager’s share of capital gains earned through a fund to be eligible for the lower tax rates applicable to long-term capital gain. [4] This is a departure from the one-year holding period that is typically required for long-term capital gain treatment.
The Final Regulations are generally helpful to taxpayers, except with respect to allocations of unrealized gain, as discussed below. However, some questions remain unresolved and fund managers should continue to exercise care in interpreting and applying the Final Regulations. As discussed further below, the majority of the provisions will not be effective until at least January 1, 2022, allowing fund managers some time to prepare and plan.
And here's another article:
IRS Set to Publish Final Rule on Federal Excise Tax | Holland & Knight LLP - JDSupra
Mr. Hoover observed that the IRS has conceded on many of the recommendations made by NBAA. He pointed out that the IRS affirmed that owner trust arrangements qualify as aircraft owners eligible for the exemption and that the IRS scrapped a pair of antiabuse rules entirely, as well as a complicated calculation involving substitute aircraft. (See " IRS Grants Some Relief in Final Aviation Excise Tax Regs ," Tax Notes Today , Jan. 12, 2021.)
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
DAC6: Adieu to EU | Katten Muchin Rosenman LLP - JDSupra
On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2) (EU Exit) Regulations 2020' (the 'Amendment Regulations').
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In the words of the Amendment Regulations, 'hallmark categories A, B, C and E [are] omitted'.
Further guidance from HMRC is expected to be forthcoming to clarify the exact extent of reporting requirements for UK intermediaries and taxpayers. For the moment, the historic lookback period relating to DAC6 — which requires a review of all arrangements where the first step in such arrangement was taken on or after 25 June 2018 — still applies for cross-border arrangements to which either of the D Hallmarks apply.
Attorney general misusing tax funds, suit says
Attorney General Leslie Rutledge regularly uses her office to promote her own political agenda over the interests of the people of Arkansas, illegally using tax money that she must be forced to repay, according to a lawsuit filed Friday.
The suit, filed by eight Arkansas residents, accuses Rutledge of exceeding her statutory authority, which restricts her office to involvement only in litigation in which the state is a direct party or where the laws, regulations or policies of the state are involved.
Quite a lot has been going on:
Treasury and IRS Release Final Regulations on Treatment of Carried Interest
Moshe Biderman, Jonathan R. Collett, Robert Richardt, and Mark Papa of CohnReznick outline the taxpayer-friendly modifications made by the Treasury Department and IRS in the final carried interest regulations released last week. The authors note that the future of this legislation remains unclear, and the Biden administration and a Democratic-controlled Congress may seek to eliminate the tax break for carried interest entirely.
The Treasury Department and IRS recently released final regulations governing the treatment of "carried interest" under tax code Section 1061.
Qatar Issues New Defense and Security Tax Exemption
The Qatar Financial Centre Authority ("QFCA") Tax Department have issued a Concessionary Statement of Practice (the "Statement") providing for an exemption to Qatar Financial Centre ("QFC") companies performing contracts in the defense and security sector in the State of Qatar.
The intent behind the Statement is to offer defense and security companies engaged in significant projects in Qatar the incentive to use the QFC as their platform.
The exemption will be granted to companies which fulfill the following substantive criteria, in addition to a few administrative criteria listed in the Statement:
Get Ahead on Your Tax Return by Answering These 15 IRS Questions
From general contact information to specific IRS regulations, this list of questions and answers delivers. Here are 15 things every taxpayer should know about the IRS:
You can call the IRS phone number at 800-829-1040 for questions about individual income tax returns. In case of a hearing impairment, call this IRS number at 800-829-4933. Be aware that the IRS takes protecting your identity very seriously and expects you to verify your Social Security or individual taxpayer identification number, date of birth, filing status, information from your prior year's return and a copy of the return you're calling about to verify you are who you say you are.
Recent Tax Shelter Disclosure Requirements in Mexico and Argentina | Carlton Fields - JDSupra
Just as the U.S. American Jobs Creation Act of 2004 amended the Internal Revenue Code to include expanded anti-tax shelter reporting obligations, new legislation in Mexico and Argentina should yield similar information that will likely impact domestic and international tax planning.
Pursuant to the Mexican Tax Code (as amended in December 2019), Mexican taxpayers and their advisors are required to report to the Mexican Tax Authority (SAT), tax structures designed or implemented to avoid the payment of income tax generated through foreign transparent entities such as LLCs, partnerships and trusts.
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