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Results: 1-8 of 8

Treasury publishes highly anticipated “withholdable payment” FATCA regulations and outlines international cooperation alternative

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2012

After months of waiting, the Treasury released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable payment” regulations on February 8, 2012

IRS offshore voluntary discosure program reopens

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • January 10 2012

On January 9, 2012, the Internal Revenue Service (the “IRS”) reopened indefinitely its offshore voluntary disclosure program (the “2012 OVDP”) to assist taxpayers in reporting undisclosed foreign accounts, assets, and income

IRS announces phased implementation of FACTA

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 19 2011

On July 14, 2011, the Internal Revenue Service (“IRS”) and Treasury Department (“Treasury”) announced a phase-in schedule which effectively delays implementation of the Foreign Account Tax Compliance Act (“FATCA”) for one year and, in some cases, until 2015

IRS unveils 2011 Offshore Voluntary Disclosure Initiative

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 14 2011

On February 8, 2011, the IRS unveiled the 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), pursuant to which taxpayers may come forward, through August 31, 2011, to report previously undisclosed foreign accounts, assets, and income

President Obama signs 2010 Tax Relief Act

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 17 2010

Today, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "Act") into law

Medicare tax on the sale of a principal residence?

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • October 13 2010

As discussed in our prior client alert, “Reconciliation Bill Codifies ‘Economic Substance’ Doctrine, Expands Medicare Taxes on High Income Earners and Imposes Reporting Requirements on Certain Payments to Corporations,” to pay for health care reform, among other revenue raisers, the Health Care Act introduced a 3.8 Medicare contribution tax (the “Medicare tax”) on unearned income (i.e., income other than from wages) of certain high income earners

Press corner

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • March 31 2010

The US tax authorities will soon launch another prosecution against a foreign bank for facilitating offshore tax evasion, a la the case against Swiss bank UBS AG, according to an IRS agent speaking with Reuters

IRS memorandum: loan origination by foreign entity through U.S. intermediary subject to U.S. tax

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • December 31 2009

On September 22, 2009, the Office of Chief Counsel of the IRS released a generic legal advice memorandum, AM 2009-010 (“Memorandum”), concluding that interest income earned by a foreign corporation with respect to loans originated by an agent in the U.S., whether dependent or independent, is subject to net income tax in the U.S. as income “effectively connected” with the conduct of a U.S. trade or business

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