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Results: 1-6 of 6

FATCA NFFE rules subject non-U.S. P&C insurers and reinsurers to burdensome reporting requirements

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • May 2 2013

The good news is that, under the recently released Foreign Account Tax Compliance Act (FATCA) regulations, most non-U.S. property and casualty (P&C

New budget proposals once again target insurance companies

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • April 15 2013

On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax

Camping on "the street": a first step in the reform of the taxation of financial instruments and products

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • January 29 2013

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain

You can’t spell “Subchapter C” without E&P: proposed Treasury regulations clarify the rules concerning the allocation of earnings and profits in tax-free transfers

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • April 17 2012

On April 13, 2012, Treasury and the Internal Revenue Service (the IRS) issued proposed regulations that aim to clarify the rule of Treas. Reg. 1.312-11(a), which concerns the allocation of earnings and profits in tax-free transfers between corporations (the Proposed Regulations

A secret no more: final Treasury regulations amend the controlled group deferred loss “supersecret rule”

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • April 17 2012

Nearly a year after issuing proposed regulations that aimed to modify the so-called “supersecret rule” of Treas. Reg. 1.267(f)-1(c)(1)(iv) (the Proposed Regulations), Treasury and the Internal Revenue Service (the IRS) issued final regulations amending that rule on April 13, 2012 (the Final Regulations

Legal alert: repeal of expanded Form 1099 reporting requirements signed into law

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • April 18 2011

On April 14, 2011, the President signed into law H.R. 4, the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (the Act), which repeals the expanded Form 1099 reporting requirements for businesses and rental property owners that had been added to the Internal Revenue Code by the Patient Protection and Affordable Care Act and the Small Business Jobs Act of 2010