Wyoming

HB 4(Chapter No. 18) effective July 1, 2007 provides for reinstatement of LPs and RLLPs within 2 years of administrative dissolution or laps of registration for failure to pay fees. Click here to read more.

HB 9 (Chapter No. 19) effective July 1, 2007 prohibits bearer shares and requires corporations to comply with new law no later than October 1, 2007. Click here to read more.

HB56 (Chapter No. 38) effective July 1, 2007 provides for registration of foreign LLLPs. Click here to read more.

Senate Bill 681

U.S. Senators Carl Levin (D-MI), Norm Coleman (R-MN) and Barack Obama (D-IL) introduced on Saturday, February 17, Bill 681 cited as “the Stop Tax Haven Abuse Act” to restrict the use of offshore tax havens and abusive tax shelters to inappropriately avoid federal taxation and for other purposes. The bill would:

1. Establish presumptions pertaining to entities and transactions involving “offshore secrecy jurisdictions” which are defined as Anguilla, Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, Bermuda, British Virgin Islands, Cayman Islands, Cook Islands, Costa Rica, Cyprus, Dominica, Gibraltar, Grenada, Guernsey/Sark/Alderney, Hong Kong, Isle of Man, Jersey, Latvia, Liechtenstein, Luxembourg, Malta, Nauru, Netherlands Antilles, Panama, Samoa, St. Kitts and Nevis, St. Lucia, St. Vincent and Grenadines, Singapore, Switzerland, Turks and Caicos Islands, and Vanuatu
2. Establish other measures to combat abuses including that would require the U.S. Department of Treasury to issue regulations requiring hedge funds and “company formation agents” to establish anti-money laundering programs similar to those required of banks
3. Provide penalties for promoting abusive tax shelter and aiding and abetting the understatement of tax liability
4. Clarify economic substance doctrine and provide penalty for understatements of tax liability lacking economic substance and deny deductions for interest on underpayments.

Click here for a statement by Carl Levin and a copy of the bill.

IRS Notice 2006-85

Recent IRS Notice 2006-85 announced new regulations for transactions occurring on or after September 2006 affecting controlled foreign corporations (CFCs) or US subsidiaries of foreign parents. Click here to read more.