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Final regulations implementing nonresident alien deposit interest reporting

Alston & Bird LLP
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USA
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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

IRS chart clarifies separate Form 8938 and FBAR reporting requirements

Alston & Bird LLP
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USA
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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

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

Alston & Bird LLP
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USA
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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

IRS provides guidance on reporting of specified foreign financial assets

Alston & Bird LLP
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USA
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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

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

Alston & Bird LLP
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USA
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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

IRS releases new priority guidance plan

Alston & Bird LLP
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USA
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September 15 2011

On September 2, 2011, the IRS and the Department of Treasury released the 20112012 Priority Guidance Plan (“Plan”) listing the topics on which they intend to publish formal administrative guidance between July 2011 and June 2012

Timeline extended for implementation of FATCA “stop tax haven abuse” legislation reintroduced

Alston & Bird LLP
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USA
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August 15 2011

The Foreign Account Tax Compliance Act (FATCA), the government’s tool against offshore tax evasion, was scheduled to become effective on January 1, 2013

Temporary suspension of new filing requirements; new proposed Subpart F income category

Alston & Bird LLP
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USA
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July 15 2011

The Hiring Incentives to Restore Employment Act (the 2010 HIRE Act) enacted new disclosure requirements (by adding new Section 6038D to the Internal Revenue Code) for tax years beginning after March 18, 2010

International update: FATCA, FBAR, voluntary disclosure

Alston & Bird LLP
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USA
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June 15 2011

As has been previously discussed, the Foreign Account Tax Compliance Act (FATCA) enacted in March 2010 was designed to detect U.S. persons who may be evading U.S. tax by holding incomeproducing assets through accounts at foreign financial institutions (FFIs) or through other foreign entities (non-financial foreign entities or NFFEs

IRS advises taxpayers to engage U.S. competent authority early

Alston & Bird LLP
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USA
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May 15 2011

At a recent meeting of tax professionals in New York, Michael Danilack, Deputy Commissioner (International) of the IRS Large Business and International Division (LB&I) and U.S. Competent Authority under tax treaties, stated that U.S. taxpayers must contact the U.S. Competent Authority in relation to a proposed treaty country tax adjustment, which implicates a U.S. correlative adjustment

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