We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
Lexology logo
  Request new password

Tola Ozim Alston & Bird LLP

Results 1 to 5 of 30



Final regulations implementing nonresident alien deposit interest reporting *

USA - May 15 2012
The United States has maintained a longstanding policy of not taxing bank deposit interest of nonresident aliens as a way in which to encourage foreign investment in U.S. banks.

Co-authors: Edward Tanenbaum.


IRS chart clarifies separate Form 8938 and FBAR reporting requirements *

USA - April 16 2012
As part of the Hiring Incentives to Restore Employment (HIRE) Act, the Foreign Account Tax Compliance Act established a new and distinct foreign asset disclosure regime under Section 6038D requiring specified persons that hold interests in “specified foreign financial assets” to attach Form 8938, the “Statement of Specified Foreign Financial Assets,” to the person’s annual federal tax or information return reporting certain information if the aggregate value of those assets exceeds certain threshold amounts.

Co-authors: Edward Tanenbaum.


Section 871(M) guidance on treatment of dividend equivalent payments *

USA - February 15 2012
On January 23, 2012, the IRS published both temporary (T.D. 9572) and proposed regulations (REG- 120282-10) under Section 871(m) regarding U.S. federal withholding tax on dividend equivalents.

Co-authors: Edward Tanenbaum.


IRS provides guidance on reporting of specified foreign financial assets *

USA - January 15 2012
The Internal Revenue Service published temporary regulations (T.D. 9567) on December 19, 2011, implementing Section 6038D, which provides that “specified individuals” who have an interest in “specified foreign financial assets” with a value of more than the applicable reporting threshold must attach new Form 8938, Statement of Specified Foreign Financial Assets, to their tax returns for tax years beginning after March 18, 2010.

Co-authors: Edward Tanenbaum.


International tax proposals included in the president’s plan for economic growth and deficit reduction *

USA - October 17 2011
On September 23, as a follow-up to the Administration’s job creation and infrastructure bill, the American Jobs Act of 2011, President Obama released draft legislation for the “President’s Plan for Economic Growth and Deficit Reduction”, which had been submitted to Congress and the Joint Select Committee on Deficit Reduction a few days before.

Co-authors: Edward Tanenbaum.


Next »