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Results: 1-10 of 22

The Treasury and IRS ease up (a little) as FATCA approaches

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 15 2014

The Foreign Account Tax Compliance Act (FATCA), enacted by the 2010 HIRE Act, generally requires foreign financial institutions (FFIs) and

IRS releases new FATCA guidance, including draft FFI Agreement

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

In Notice 2013-69, the IRS introduced a long-awaited draft Foreign Financial Institution (FFI) Agreement and additional guidance under the Foreign

IRS says income on Federal Reserve collateral of foreign bank must be allocated between ECI and non-ECI

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

In a recently released Technical Advice Memorandum (TAM) 201325012, the IRS said that interest earned by a foreign bank on notes pledged as

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

IRS announces new guidance on FATCA timelines, gross proceeds and grandfathered obligations

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

On October 24, 2012, the IRS issued Announcement 2012-42, presenting additional guidance for effectuating the Foreign Account Tax Compliance Act (FATCA

Here they come: first FATCA intergovernmental agreement signed

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

In July of this year, Treasury released a model intergovernmental agreement (IGA) that offered a work-around to foreign entities whose countries of residence have laws preventing the entities from complying directly with FATCA and reflected a cooperative intergovernmental approach to tackling international tax evasion

International tax advisory - U.S. Treasury releases model FATCA intergovernmental agreement

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

In February 2012, Treasury issued a joint statement with France, Germany, Italy, Spain and the United Kingdom regarding plans for an intergovernmental approach to implement the Foreign Account Tax Compliance Act (FATCA

IRS updates 2012 Offshore Voluntary Disclosure Program with new FAQs

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

On June 26, 2012, the IRS released new frequently asked questions (FAQs) on the 2012 Offshore Voluntary Disclosure Program (OVDP) that was announced in January

FATCA update

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

As reported in our March 15, 2012, Special Alert Advisory, the Internal Revenue Service on February 8, 2012, issued a massive set of proposed regulations under the Foreign Account Tax Compliance Act (FATCA

U.S.Netherlands Competent Authority agreement covering limited fund mutual accounts

  • Alston & Bird LLP
  • -
  • Netherlands, USA
  • -
  • June 15 2012

In late May 2012, the Competent Authorities of the United States and the Netherlands entered into an agreement to clarify application of the United States-Netherlands income tax treaty (the “Treaty”) with respect to U.S. source dividends and interest paid to a limited fund for mutual account (LFMA