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Results: 11-20 of 341

STARS transaction rejected

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 20 2013

On Feb. 11, 2013, a regular Tax Court opinion was issued in a case that the opinion said was of first impression, ruling against Bank of New York

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

IRS issues game-changing regulations interpreting health care reform’s pay or play requirement

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 6 2013

Beginning in 2014, "applicable large employers" become subject to new rules prescribed in Internal Revenue Code Section 4980H ("4980H Rules"), which

The worthless subsidiary problem

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 31 2013

LPCiminelli Interests, Inc. v. United States, 110 AFTR 2d 2012-6631 (W.D. N.Y. 2012) ruled that a consolidated group did not have to amend its

IRS may apply economic substance doctrine to securities lending transactions entered to avoid U.S. withholding tax

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

In generic legal advice released in November 2012 (AM 2012-009), the Chief Counsel's Office, applying the economic substance doctrine, disregarded a

Global banks being audited

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 7 2013

All global banks currently being audited by the IRS, which have engaged in cross-border withholding planning for clients, should take careful notice of AM

Section 355 no-rule tightened

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 2 2013

The IRS issued its annual no-ruling revenue procedure, Rev. Proc. 2013-3, which added several items relating to Section 355 distributions. The IRS is

Federal tax advisory - eliminating a domestic sandwich LTR 201250004

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 1 2013

LTR 201250004 involved a domestic corporate Parent's purchase of a foreign group that had one domestic subsidiary. This is a common situation and Parent

Non-355 ruling

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 31 2012

Sometimes, a corporation wants to distribute stock of a subsidiary to its shareholders in a taxable transaction and does not want Section 355 to apply to

The FATCA Model 2 intergovernmental agreement

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

In late July, the Treasury released a Model 1 Intergovernmental Agreement (IGA) to facilitate foreign financial institutions’ (FFIs) compliance with FATCA reporting rules

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