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Results: 1-9 of 9

Final regulations implementing nonresident alien deposit interest reporting

  • Alston & Bird LLP
  • -
  • USA
  • -
  • 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

International update: FATCA, FBAR, voluntary disclosure

  • Alston & Bird LLP
  • -
  • USA
  • -
  • 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

Industries react to FATCA notice in comment letters

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 15 2010

Enacted on March 18, 2010, as part of the HIRE Act, the Foreign Account Tax Compliance Act (FATCA) provisions require reporting of U.S. persons who hold accounts in foreign financial institutions or who own certain interests in foreign entities that hold such accounts

Government fails to prove taxpayer “willfully” concealed offshore bank accounts

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 20 2010

Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign Bank and Financial Accounts

Government fails to prove taxpayer “willfully” concealed offshore bank accounts

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 15 2010

In United States v. J. Bryan Williams, a Virginia District Court found that the Government had failed to meet its burden to establish that a taxpayer willfully failed to report his interest in foreign bank accounts that were omitted from the individual’s 2000 tax return

Guidance concerning foreign bank account (FBAR) filing requirements released

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 15 2010

On February 26, 2010, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department (“Treasury”) issued a Notice of Proposed Rulemaking proposing to amend the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR

Changes made to the Foreign Account Tax Compliance Act

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 15 2010

On December 9, 2009, the House of Representatives approved H.R. 4213, the Tax Extenders Act of 2009 (TEA), which includes portions of the Foreign Account Tax Compliance Act (H.R. 3933 and S. 1934) (FATCA), introduced on October 27, 2009, by Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York

Additional deadline for voluntary disclosure program

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 16 2009

The IRS is considering imposing a deadline on information reports filed by individuals who have sought to voluntarily disclose assets held in offshore accounts before the special program deadline

U.S. lawmakers introduce Foreign Account Tax Compliance Act of 2009

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 16 2009

On October 27, 2009, Senator Max Baucus (D-MT) and Representative Charles Rangel (D-NY) introduced the Foreign Account Tax Compliance Act of 2009 (H.R. 3933, S. 1934) (the “Bill”) in the U.S. Congress