September 2009

The Internet Corporation for Assigned Names and Numbers (ICANN) and the U.S. Department of Commerce’s National Telecommunications and Information Administration (NTIA) announced today that it has reached an agreement  that establishes a long-lasting framework for the technical coordination of the Internet’s domain name and addressing system (DNS). 

ICANN and NTIA executed a new Affirmation of Commitments that completes the transition of the technical management of the DNS to a multi-stakeholder, private-sector-led model. The Affirmation ensures accountability and transparency in ICANN’s decision-making with the goal of protecting the interests of global Internet users.  The Affirmation also establishes mechanisms to address the security, stability, and resiliency of the Internet DNS as well as promote competition, consumer trust, and consumer choice. Continue Reading ICANN and U.S. Department of Commerce Sign New “Affirmation of Commitments”

The Internal Revenue Service has released an internal memorandum indicating that it will give close audit scrutiny to offshore hedge funds that engage in lending activities with U.S. residents.  A number of hedge funds have relocated to the U.S. Virgin Islands to take advantage of the Territory’s Economic Development Commission (EDC) Program which exempts such funds from 90% of the federal income tax liability.  Although owner of EDC beneficiary companies can similarly exempt their income from the company from federal income tax if they are Virgin Islands residents, past practice has led to the hedge funds providing loans to owners who are not Virgin Islands residents. 

Hedge funds that engage in direct or indirect lending activities involving U.S. borrowers are impacted by this IRS action and should immediately review their lending practices in light of the IRS’s indication that it will pursue vigorous enforcement in this area.

Continue Reading IRS Scrutizes Offshore Hedge Fund Lending

Retired? Over 70½? It may be time to see your tax advisor about September 2009 changes to the Required Minimum Distribution rules. The Internal Revenue Service in Notice 2009-82 just announced guidance relating to the waiver of 2009 Required Minimum Distribution (“RMD”) rules which also apply to Virgin Islanders.Continue Reading Changes to Required Minimum Distribution Rules Impact Virgin Islanders