American Council of Life Insurers Issues Public Comment on IRS Proposed Rule
Targeted News Service
Mandana Parsazad, vice president for taxes and retirement security, at the
American Council of Life Insurers have issued a public comment on the
Internal Revenue Service proposed rule entitled Guidance: Passive Foreign Investment Companies and the Treatment of Qualified Improvement Property under the Alternative Depreciation System . The comment was written on
April 14, 2021, and posted on
April 16, 2021:
Treasury published final regulations (REG-111950-20; the Final Regulations ) in the
Federal Register to address Passive Foreign Investment Companies ( PFICs ) providing guidance on the treatment of income and assets of a foreign corporation for purposes of the PFIC rules and on the exception from passive income under section 1297(b)(2)(B) ( PFIC insurance exception ) of the Internal Revenue Code of 1986, as amended (the Code )./1
Revisions to or Replacements of Working Capital Safe Harbor Plans
Although the final Treasury regulations, Notice 2021-10, and Notice 2020-39 helpfully provide a QOZB with an additional 24 months (on top of the existing 31-month deployment allowance for any single infusion of cash into a QOZB) to expend its working capital assets in light of the COVID-19 pandemic, they do not exempt the QOZB from the requirement that it must do so in a manner substantially consistent with the original, pre-disaster written plan. As we noted
here at the time of the publication of the pandemic relief for QOFs and QOZBs, given that many such vehicles were formed to facilitate investment in business sectors heavily disrupted by the pandemic, the failure to expressly allow written plan revisions to adapt to the effects of the pandemic was a serious hole in the otherwise favorable IRS pandemic guidance for QOFs and QOZBs, and left many advisors hoping that their clients could make such revisions and rel
Dubai, UAE, 14
April 2021: Dubai International Financial Centre (DIFC), the leading international financial hub in the Middle East, Africa and South Asia (MEASA) region, has issued a consultation paper proposing to issue Intellectual Property Regulations under the Intellectual Property Law No. 4 of 2019. The Proposed Regulations will facilitate the administration and enforcement of the DIFC IP Law and enhance the regulatory framework in DIFC.
The Proposed Regulations deal with the requirements concerning intellectual property infringement complaints to the DIFC Commissioner of Intellectual Property (IP), the inspections and investigations that the IP Commissioner may carry out in dealing with such complaints, and the requirements for issuing directions in respect thereof. The Proposed Regulations will establish a Register of Experts, which the IP Commissioner can refer to when investigating complaints, and also covers the ability of the IP Commissioner to cooperate with relevant fe
Dubai International Financial Centre (DIFC), the leading international financial hub in region, has issued a consultation paper proposing to issue Intellectual Property Regulations under the Intellectual Property Law No. 4 of 2019.
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This is an update on recent events in the cessation of the London Inter-bank Offered Rate (LIBOR):
InterContinental Benchmark Exchange (ICE), the organization that administers and announces LIBOR, and the United Kingdom’s Financial Conduct Authority (FCA), ICE’s regulator, announced on 5 March 2021:
LIBOR for most currencies and maturities will cease after 31 December 2021.
U.S. dollar LIBOR for overnight, one-month, three-month, six-month, and 12-month maturities will cease after 30 June 2023.
LIBOR is not expected to become unreliable prior to the cessation date applicable to the relevant currency and maturity.