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Results: 1-8 of 8

Final FATCA regulations are finally here

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 15 2013

On January 17, 2013, the U.S. Treasury and the IRS issued long-awaited final regulations under the Foreign Account Tax Compliance Act (FATCA

FATCA private fund executive summary

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 1 2012

The IRS recently issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that provide additional FATCA guidance on due diligence, withholding and reporting obligations, carve-outs and exceptions to FATCA’s applicability, and a new timeline for implementation

Summary of the proposed FATCA regulations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 15 2012

On February 8, 2012, the IRS issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that build upon prior FATCA notices issued by the IRS

IRS issues proposed regulations on the federal income tax classification of certain series

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 16 2010

On September 13, 2010, the Internal Revenue Service (IRS) issued proposed regulations (the "Proposed Regulations") on the federal income tax classification of certain "series organizations" (e.g., certain domestic series limited liability companies, series partnerships, series trusts, protected cell companies and similar arrangements, and certain foreign series or cell companies engaged in the insurance business

Tax court finds a particular “variable prepaid forward” arrangement to be a current sale

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 29 2010

In 2000, the Anschutz Company (the “Taxpayer”) held appreciated publicly traded stock (through a qualified subchapter S subsidiary) that it wanted to monetize without triggering taxable gain, while simultaneously protecting itself from any future declines in the price of such stock

Treasury relaxes test for re-testing debt status

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 9 2010

The troubled economic times have required many modifications of distressed debt instruments

Expensing royalty fees

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 1 2010

This recent decision allowed the immediate deduction of license royalty payments as they accrued on the sale of the licensed inventory, rather than requiring the royalties to be capitalized into inventory

IRS will not challenge REMIC status for certain loan modifications made in connection with the Home Affordable Modification Program

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 13 2009

On April 10, 2009, the Internal Revenue Service (IRS) issued Revenue Procedure 2009-23 (the "Revenue Procedure") and Notice 2009-36 (the "Notice"), to provide guidance regarding the effects of the Home Affordable Modification Program (HAMP) on real estate mortgage investment conduits (REMICs) and certain trusts

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