• Deferred taxes on offshore fund incentive fees may not be dead after all

    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).
  • What’s new in the Affordable Care Act

    Since the healthcare law was passed, the number of changes to its implementation and rules has created confusion for not only employers, but also employees. Our recent webinar discusses the latest modifications and what they mean to you. Specifically, they address the employer mandate (pay-or-play rules), the impact of temporary employees on large employers, and disclosures and reporting requirements.
  • Tax allocation agreement revision required by Oct. 31

    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”.