Tax Analysts provides news, analysis, and commentary on tax-related topics relating to financial institutions, including banks, insurance companies, regulated investment companies, hedge funds, private equity funds, security brokers, and security traders. Financial institutions coverage also include in-depth analysis of foreign account tax compliance act (FATCA) and the Justice Department’s Swiss bank program.
In 2013, the Justice Department announced opportunities for banks to avoid prosecution through payment of fines, disclosure of account holders, and compliance with FATCA. In 2010 Congress enacted FATCA to increase reporting of foreign financial assets. With the help of financial institutions, the U.S. hopes to track financial assets across the world.
In addition to initiatives such as the Swiss bank program and FATCA, Tax Analysts provides coverage of the tax implications of financial institution’s activities, including the taxation of financial instruments and trader or broker activities. Most financial institutions, such as banks, are taxed on a marked-to-market basis under section 475, which requires mark to market tax accounting for dealers in securities. Section 475 also provides a mark to market election for dealers in commodities and traders in securities or commodities.
Insurance company taxation is subject to subchapter L of the tax code. Subchapter L provides a special set of rules for life insurance and property and casualty insurance companies, given their unique business models and importance to the economy. Tax Analysts coverage also includes reinsurance and hedge fund activity in the insurance industry.
Subchapter M controls regulated investment companies, also known as mutual funds, money market funds, and real estate investment trusts. These entities are not taxed at the entity level but are subject to rules about distributing profits to shareholders and the types of investments they can make.