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Results: 1-10 of 14

CFPB proposes revisions to remittance rule and extension of effective date

  • Sidley Austin LLP
  • -
  • USA
  • -
  • January 25 2013

The Consumer Financial Protection Bureau has released a proposed rule and request for comments outlining a limited set of revisions to its previously

IRS releases final FATCA regulations

  • Sidley Austin LLP
  • -
  • USA
  • -
  • January 18 2013

The IRS has released final regulations under the Foreign Account Tax Compliance Act ("FATCA"). FATCA was enacted in 2010 and imposes a 30

IRS announces new dates for FATCA implementation

  • Sidley Austin LLP
  • -
  • USA
  • -
  • November 2 2012

The IRS has announced that the following new timeline for the implementation of several provisions of the Foreign Account Tax Compliance Act (“FATCA”) will be adopted in final regulations and has also expanded the definition of “grandfathered obligation” under FATCA

IRS releases FATCA proposed regulations

  • Sidley Austin LLP
  • -
  • USA
  • -
  • February 9 2012

On February 8, 2012, the Treasury Department released proposed regulations under legislation that requires foreign financial institutions (including foreign banks, brokers, hedge funds and securitization vehicles such as CLOs) to report to the IRS information regarding U.S. account holders

IRS releases supplemental FATCA guidance

  • Sidley Austin LLP
  • -
  • USA
  • -
  • April 21 2011

The IRS has issued supplemental guidance regarding recently enacted foreign financial account reporting requirements in the Internal Revenue Code under the Foreign Account Tax Compliance Act ("FATCA"

IRS issues private letter ruling on equity treatment of municipal bond fund’s liquidity enhanced preferred stock

  • Sidley Austin LLP
  • -
  • USA
  • -
  • March 1 2011

A private letter ruling ("PLR") issued by the Internal Revenue Service ("IRS") on February 16, 2011, on the equity treatment of closed-end fund liquidity enhanced preferred stock, confirms that the IRS will continue following the principles of expired IRS Notice 2008-55, which allowed closed-end municipal bond funds to refinance traditional auction rate or remarketed preferred stock ("ARPS") with liquidity enhanced preferred stock, such as variable rate demand preferred stock ("VRDP"

New revenue procedure makes it easier for REMICs to release liens in the case of commercial mortgage loans secured by multiple real properties

  • Sidley Austin LLP
  • -
  • USA
  • -
  • October 8 2010

Revenue Procedure 2010-30 (“Rev. Proc. 2010-30”) makes it easier for a REMIC holding commercial mortgage loans secured by multiple properties to release the mortgage lien on one or more of those properties without jeopardizing the REMIC’s tax status or exposing it to prohibited transaction taxes

Hybrid capital product development: Focusing on Tier 1 and other hybrid capital products

  • Sidley Austin LLP
  • -
  • European Union, Global, USA
  • -
  • March 23 2010

It is our pleasure to provide you with the eleventh edition of Sidley's publication on hybrid capital product development

IRS provides relief from FBAR reporting for pre-2010 interests in hedge funds and private equity funds; FINCEN issues proposed FBAR regulations

  • Sidley Austin LLP
  • -
  • USA
  • -
  • March 2 2010

On February 26, 2010, the IRS released Announcement 2010-16 and Notice 2010- 23, both relating to the reporting obligations on Form TD F 90-22 1, the Report of Foreign Bank and Financial Accounts ("FBAR"

Final regulations expand tax safe harbors for certain common modifications of REMIC-held commercial mortgage loans

  • Sidley Austin LLP
  • -
  • USA
  • -
  • September 23 2009

On September 15, 2009, theTreasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published T.D. 9463, finalizing regulations (the “New Regulations”) that expand a REMIC’s ability to make certain common modifications to commercial mortgage loans without jeopardizing the REMIC’s tax status or exposing it to prohibited transactions taxes