- In the recently published Revenue Ruling 2014-18, the Internal Revenue Service (IRS) concluded that certain nonqualified stock options (NSOs) or stock appreciation rights (SARs) would not be subject to the anti-deferral rules of Internal Revenue Code section 457A (section 457A). Generally, section 457A prohibits the deferral of income for service providers that perform services for nonqualified entities (i.e., foreign corporations based in offshore tax havens, entities substantially owned by tax-exempt organizations, or other tax-indifferent parties).
- In June 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued an addendum to the “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure”.
- Recently, project sponsors have combined New Markets Tax Credits with EB-5 financing in order to strengthen the overall financing structure of the projects. While significant benefits can be achieved, several structuring challenges need to be overcome.
- The Council of the District of Columbia approved an annual budget with a number of major tax changes for businesses and their owners.
- The IRS issues new guidelines, making it easier for businesses to claim R&D credits.
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