Martine Seiden Agatston
Associate
Martine Seiden Agatston is an associate in the Tax Department.
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On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”), which provides that a repatriation deemed to have been received by a registered investment company (a “RIC”) under Section 965 (enacted as part of the 2017 tax reform act, commonly known as the “Tax Cuts and Jobs Act” or … Continue Reading
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in cross-border transactions, and this post describes them in general terms without all of their fine details. The discussion of foreign … Continue Reading
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will affect every US taxpayer, including participants in the capital markets. The purpose of … Continue Reading
On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online.[1] These additional FAQs clarify recent temporary regulations (the “Temporary Regulations”) requiring that a beneficial owner withholding certificate contain a foreign taxpayer identification number (“TIN”) and, … Continue Reading
The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”)[1] reducing from ten years to five years the recognition period for the corporate-level tax imposed on certain property dispositions by a real estate investment trust (“REIT”) or a regulated investment company (“RIC”) under Section 337(d), and … Continue Reading
As noted in our January 5, 2017 client alert, FinCEN issued Notice 2016-1, which extends the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2018. Please click … Continue Reading
New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs
Impact of Recent Tax Legislation on M&A Transactions
By Alan Parnes, Amanda H. Nussbaum, Abraham Gutwein, Martin T. Hamilton, Richard M. Corn, Malcolm Hochenberg, Amy Zelcer, Martine Seiden Agatston and Kathleen R Semanski on Posted in Corporate Taxation, Cost Recovery, In the news, International Taxation, Mergers & Acquisitions, Partnership Taxation, Tax Reform
New Tax Law (H.R. 1): Key Highlights Related to Interest Bearing Debt
IRS Updates FATCA FAQs, Addresses January Temporary Regulations
IRS Issues Final Regulations on REIT and RIC Conversion Transactions
By Martin T. Hamilton, Martine Seiden Agatston and Timothy Donovan on Posted in Real Estate, REITs
Extension of FBAR Filing Deadline for Certain Filers
By Amanda H. Nussbaum, Abraham Gutwein, Amy Drais and Martine Seiden Agatston on Posted in International Taxation
