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Tax Law Roundup current law developments in U.S. taxation

Category Archives: Financial Products

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IRS Treats U.S. Fund Manager as Agent of Foreign Investor – Subjecting Investor to US Trade or Business Taxation

Posted in Financial Products, International, Lending

In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund.  This conclusion is consistent with an earlier 2009 memorandum that similarly found that the activities of agents… Continue Reading

Senate issues 8th Tax Reform Paper: Types of Income and Business Entities

Posted in Compensation, Debt vs. Equity, Financial Products, Legislative, REITs, S corporation, Tax reform

The Senate Finance Committee issued its 8th tax reform paper, discussing the tax treatment types of income (e.g., ordinary, wages, capital gains) and business entities (e.g., C corporations, pass-throughs, RICs, and REITs).  The report also addresses the disparate treatment between debt and equity and financial product reform.  For pdf version click here.  This follows the… Continue Reading

Ways and Means Releases Discussion Draft of Financial Product Tax Reform

Posted in Financial Products, General, Legislative, Tax reform

  On January 24 the chair of the House Ways & Means Committee released proposals to reform the taxation of financial products.  The reforms include: Mark-to-market taxation for speculative financial investments.  Specifically the draft would require taxpayers engaged in speculative financial activity—but not business hedging against common risks—to mark certain financial derivative products to fair… Continue Reading