The proposed expansion of New York's real estate transfer tax, cybersecurity requirements for financial services entities, and more in this issue of Fund Forum

2 min

This issue of Venable's Fund Forum provides (i) a discussion of the proposed expansion of New York State's Real Estate Transfer Tax, (ii) a summary of the New York State Department of Financial Services' mandatory cybersecurity requirements for financial services entities, (iii) information on recent IRS scrutiny of micro-captive insurance companies, (iv) details on recent IRS guidance regarding the accumulated earnings tax, and (v) a spotlight on our team and panel discussion at the upcoming SIFMA conference in San Diego.

business concepts

Proposed Expansion of New York State Real Estate Transfer Tax

In New York State's proposed Fiscal Year 2018 budget, Governor Andrew Cuomo has added an amendment to New York State real estate transfer tax law affecting partnerships, LLCs, S-Corps, and non-publicly traded C-Corps with fewer than 100 shareholders.

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data security

New York's Department of Financial Services Finalizes Cybersecurity Requirements for Financial Institutions

On March 1, 2017, the New York State Department of Financial Services' mandatory cybersecurity requirements for financial services entities became effective, with implementation to occur within 180 days (or by September 1, 2017). The requirements broadly cover all entities operating under or required to operate under DFS licensure, registration, or charter, or which are otherwise DFS-regulated, as well as, by extension, unregulated third-party service providers to regulated entities.

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Are You "Captive" in Your "Self-Insurance"?

Recent IRS actions with respect to "micro-captive" insurance companies warrant heightened tax scrutiny of "self-insured" businesses in the mid-market M&A space. Prospective investors looking at potential M&A targets in the mid-cap market should carefully review the potential targets' insurance practices.

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financial charts

Blocker Corporation Meets Accumulated Earnings Tax—Really?

In Chief Counsel Advice 201653017, released on December 30, 2016, the National Office of the Office of Chief Counsel, Internal Revenue Service, advised an IRS field office that the "accumulated earnings tax" applied to a "blocker" corporation in a hedge fund investment manager's ownership chain. This is significant for the fund community.

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SIFMA C&L 2017 Annual Seminar

SIFMA Compliance and Legal Society Annual Seminar

March 19-22, 2017 | Marriott Marquis San Diego Marina

If you are attending SIFMA's annual conference in San Diego, we hope to see you there! Be sure to attend Michael Manley's panel, "Privilege and Work Product Protections: Ethical Considerations for In-House Teams," on March 22 from 10:45 a.m. to 12:00 p.m. Venable's Don Andrews, George Kostolampros, and Kara Ward will also be in attendance.


Read past issues of Venable's Fund Forum.