IRS Finds US Trade Or Business For Foreign Fund; IRS Intends To Audit Fund Lending Activities

In Chief Counsel Advice 201501013 (CCA), issued on January 5, 2015, the Internal Revenue Service (IRS) considered whether a fund manager (US Manager) that made loans and acted as a stock underwriter through its US office and as an independent agent on behalf of a foreign fund (Fund) caused the Fund and its foreign feeder (Foreign Feeder) to have a US trade or business under the Internal Revenue Code of 1986, as amended (Code).  […]

By |January 10th, 2015|

United States: Reminder To Perform Annual ISO/ESPP Reporting In January 2015

As discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require Employers to annually furnish each employee who exercised incentive stock options (“ISOs”) or sold or otherwise transferred shares acquired under an employee stock purchase plan (“ESPP”) during a year with a detailed information statement by January 31 of the following year. In addition, Employers must file […]

By |January 10th, 2015|

IRS Finds US Trade Or Business For Foreign Fund; IRS Intends To Audit Fund Lending Activities

In Chief Counsel Advice 201501013 (CCA), issued on January 5, 2015, the Internal Revenue Service (IRS) considered whether a fund manager (US Manager) that made loans and acted as a stock underwriter through its US office and as an independent agent on behalf of a foreign fund (Fund) caused the Fund and its foreign feeder (Foreign Feeder) to have a US trade or business under the Internal Revenue Code of 1986, as amended (Code).  […]

By |January 10th, 2015|