Archive - October 2011
The Foreign Fund's FATCA Dilemma - A New White Paper by Navigant October 20, 2011
I've been posting some of the FATCA white papers prepared by Navigant's FATCA task force on this blog. Continuing this practice, I just received the latest one from my colleague Rich Kando at Navigant's Disputes and Investigation Practice and I wanted to share it with the readers. This presentation deals specifically with foreign funds and some of the specific impact assessment those funds need to be doing right now in preparation for FATCA. Here is the paper:
Carried Interest Proposal Blocked in the Senate Yet Again October 12, 2011
This will be a short post. Recently I mentioned on this blog that the Carried Interest legislation is resurfacing again courtesy of Obama’s efforts and the American Jobs Act of 2011. In my post I reasoned that, well, this time the effort may have some legs considering the economic and political climate in the country. Oh, was I wrong! Contrary to my guess, and making my guess look that sillier, the Senate shut down the bill yesterday in a pretty uniform fashion with all Republicans voting against opening a debate. Democrats are disappointed of course, and if you judge by the post vote...
A Multimillion Dollar Settlement Allocation Slap on the Wrist October 06, 2011
Investment funds litigate and settle cases like many other taxpayers. The settlement process is usually handled by litigators, in-house or otherwise. Some litigators are attuned and aware of the tax issues related to settlements and others are not. As it may be the case, settlements have significant tax consequences, and as the recent decision of Healthpoint v. Commissioner, T.C. Memo. 2011-241 (October 3, 2011) demonstrates, could lead to further tax related litigation and penalties. What’s usually at stake? The two key tax elements of a tax settlement are character of income inclusion...