IRS Initiates Second Offshore Amnesty Program

On February 8th, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative for taxpayers with undisclosed income in foreign bank accounts to come forward and get current with their taxes. By coming forward voluntarily, taxpayers can generally avoid criminal prosecution and pay a reduced penalty. To participate, taxpayers must submit several documents and amended…

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Obama FY 2012 Budget Proposal Again Targets Carried Interests

On February 14, 2011, the Obama administration released its proposal for the FY 2012 budget. Several tax policy issues pursued by the Obama administration in previous years were again included in the budget proposal, including the taxation of “carried interests” as ordinary income. The movement to tax “carried interests” as ordinary income made significant headway…

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IRS Announces Second Chance for Offshore Account Holders, Deadline of August 31, 2011

On February 8th, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (the “2011 OVDI”) for taxpayers with undisclosed income in foreign bank accounts to come forward and get current with their taxes.  Approximately 15,000 taxpayers participated in a similar program offered in 2009, where in exchange for a reduced penalty structure and the…

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New IRS Reporting Applicable to Employers that Grant ISOs or Sponsor ESPPs

Prior to 2010 tax years, Section 6039 of the Internal Revenue Code, required that employers provide information statements to their employees when such employees either (i) exercised grants of incentive stock options (ISOs) or (ii) purchased shares under an employee stock purchase plan (ESPP). For years 2010 and later, an updated set of rules and…

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