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Tax Tips For Start-Ups: Sales And Employment Withholding Tax
Tax ranks high among the many structural issues a start-up needs to consider. In her article in the Metropolitan Corporate Counsel, Alyssa Forslund, notes that even tax responsibilities that seem straightforward – such as collecting sales tax and setting up withholding for employees – can be challenging and need to be approached carefully
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Nonprofit Alert: United States Investors in Offshore Hedge Funds Should Consider Filing the Report of Foreign Bank and Financial Accounts (FBAR), 2009-06-23

TD F 90-22.1 is required to be filed for all accounts where a U.S. person or entity has a financial interest or signature authority in foreign financial accounts if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year. These relationships are reported on the calendar year by filing Form TD F 90-22.1 with the Department of the Treasury on or before June 30, of the succeeding year.

On June 12, three IRS personnel participated in a teleconference with a law firm that was designed to address open questions regarding the TDF 90-22.1 filing for calendar year 2008 that must be filed by June 30. It was their position (not official IRS position at this point) that an offshore hedge fund is a “foreign financial account” for this purposes and that, therefore, every U.S. investor in an offshore hedge fund should file a TDF 90-22.1 Form, whether or not the fund has any offshore bank or securities accounts. While the IRS’s position on hedge funds is not official, it does carry substantial weight and should be considered.

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