Insights & News

Tax Insights, November 22, 2016
Tracking Tax News You Need to Know

November 22, 2016
NYSBA Submits Report on Targeted Capital Account Agreements
The New York State Bar Association Tax Section submitted a report commenting on issues relating to partnerships that provide for preferred returns to one or more partners in response to a request by the Treasury Department and the IRS for comments regarding certain issues relating to partnerships that use "targeted capital account agreements." The report focuses on issues regarding preferred equity in partnerships that use targeted capital account agreements, including how items of partnership income, gain, deduction and loss should be allocated in respect of an accreting preference, and the extent to which the economic accrual of a preferred return gives rise to a guaranteed payment under Section 707(c) (section references are to the Internal Revenue Code of 1986, as amended).

SIFMA Seeks Delay of Dividend Equivalent Regulations' Effective Date
The Securities Industry and Financial Markets Association (SIFMA) has requested that the effective date of the Section 871(m) regulations be delayed.

IRS Releases Practice Unit on FICA Taxes for Workers Abroad and Self-Employed Workers Abroad
The IRS made available international practice units on (1) the requirement that FICA taxes be paid by U.S. citizens and resident aliens who work abroad for a U.S. employer or for a foreign affiliate of a U.S. employer that agreed with the IRS to pay FICA taxes on behalf of all U.S. citizens and resident aliens employed by its foreign affiliate and (2) the requirement that self-employed U.S. citizens and resident aliens pay self-employment tax if their net earnings from self-employment equal or exceed $400 regardless of whether the self-employment activities occur or the individual resides within the U.S.

Qatar-U.S. and Kosovo-U.S. FATCA IGA Competent Authority Arrangements Available
The competent authorities of the U.S. and Qatar and the U.S. and Kosovo have each signed an arrangement under the jurisdictions' respective 2015 intergovernmental agreement to implement the information reporting and withholding tax provisions of FATCA.

Saudi Arabia-U.S. FATCA Agreement and MOU on FACTA Agreement Available
The text is available of the agreement signed by Saudi Arabia and the U.S. to improve international tax compliance and implement the information reporting and withholding tax provisions of FATCA. The U.S. and Saudi Arabian authorities have also signed a memorandum of understanding regarding the agreement.

Information contained in this publication should not be construed as legal advice or opinion or as a substitute for the advice of counsel. The articles by these authors may have first appeared in other publications. The content provided is for educational and informational purposes for the use of clients and others who may be interested in the subject matter. We recommend that readers seek specific advice from counsel about particular matters of interest. 

Copyright © 2016 Stradley Ronon Stevens & Young, LLP. All rights reserved.

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