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On Dec. 13, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations (the Proposed Regulations) that provide certain guidance and relief from the regulatory burden associated with Sections 1471 through 1474 of the Internal Revenue Code (IRC), commonly referred to as Foreign Account Tax Compliance Act (FATCA), as well as with respect to withholding under Chapter 3 of the IRC (Withholding of Tax on Nonresident Aliens and Foreign Corporations). The Proposed Regulations…
On Nov. 26, 2018, the IRS issued proposed regulations under the Internal Revenue Code (IRC) § 163(j) enacted by the Tax Cuts and Jobs Act of 2017 (the Proposed Regulations). Generally, IRC § 163(j) limits certain taxpayers’ business interest expense deduction to the sum of (i) the taxpayer’s current year business interest income, (ii) 30 percent of the taxpayer’s adjusted taxable income (ATI) from a trade or business, and (iii) certain floor plan financing interest…
Many blockchain companies are using a largely unregulated means of raising funds, commonly known as an initial coin offering (ICO).[1]  An ICO consists of the issuance of a newly generated cryptocurrency (generally referred to as a token) that runs on blockchain technology, in exchange for fiat currency (such as U.S. dollars) or other cryptocurrencies like bitcoin or ethereum. Broadly, tokens can either be classified as “utility tokens,” which provide users with access to…
Come the end of September 2016, the Israeli Tax Authority will start forwarding data collected on U.S. citizens and green card holders with financial accounts in Israel to the U.S. Internal Revenue Service (IRS). This transferring of information is part of FATCA (the U.S. Foreign Account Tax Compliance Act of 2010), based on an agreement between Israel and the United States. While FATCA applies on a worldwide basis, the U.S. has entered into intergovernmental agreements (IGAs)…