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Grand jury indicts Swiss lawyer and banker in tax evasion scheme

Katten Muchin Rosenman LLP
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USA
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April 26 2013

A New York federal grand jury recently indicted a Swiss lawyer and bank executive for their roles in allegedly assisting US citizens with hiding

IRS delays implementation of FATCA tax reporting rules

Katten Muchin Rosenman LLP
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USA
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October 26 2012

The Internal Revenue Service this week released Announcement 2012-42 (the Announcement), which postpones until 2014 the need for foreign hedge funds and private equity funds to request Foreign Account Tax Compliance Act (FATCA) information and documentation from their investors

IRS releases guidance on foreign financial asset reporting

Katten Muchin Rosenman LLP
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USA
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February 1 2012

The Foreign Account Tax Compliance Act, enacted in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act, requires certain individuals to file a statement with their United States income tax returns to report interests in “specified foreign financial assets” (SFFA) if the aggregate value of those assets exceeds specific thresholds

Extension and new guidance for the voluntary disclosure initiative for undisclosed foreign assets

Katten Muchin Rosenman LLP
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USA
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June 10 2011

On June 2, 2011, the IRS provided additional guidance regarding its 2011 offshore voluntary disclosure initiative (OVDI) in the form of revised frequently asked questions (FAQs

IRS announces the second voluntary disclosure initiative for undisclosed foreign financial accounts

Katten Muchin Rosenman LLP
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USA
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February 14 2011

On February 8, 2011, the IRS announced a special voluntary disclosure initiative that will be available through August 31, 2011, for taxpayers who have undisclosed foreign financial accounts

New guidance on loan modifications: IRS finalizes rules on issuer’s credit quality and provides a safe harbor for REITs

Katten Muchin Rosenman LLP
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USA
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January 7 2011

On January 6, the Internal Revenue Service issued final regulations (T.D. 9513) under U.S. Treasury Department Regulation Section 1.1001-3 clarifying that a change in the issuer’s credit quality between the issue date and the modification date of a debt instrument is not considered in determining the nature of the instrument or property that results from modification of the debt instrument

HIRE Act affects foreign trusts and imposes additional requirements on U.S. persons with foreign accounts

Katten Muchin Rosenman LLP
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USA
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March 22 2010

On March 18, President Obama signed the Hiring Incentives to Restore Employment Act (H.R. 2847) (the “Act”), which includes several unrelated revenue raising provisions affecting foreign entities and individuals with certain foreign assets that were originally proposed as part of the Foreign Account Tax Compliance Act of 2009

Treasury, IRS issue proposed regulations and guidance addressing FBAR reporting requirements for retirement plans

Katten Muchin Rosenman LLP
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USA
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March 5 2010

At the end of February, the Financial Crimes Enforcement Network (FinCEN) bureau of the U.S. Department of the Treasury issued proposed amendments to the Bank Secrecy Act regulations governing Reports of Foreign Bank and Financial Accounts, commonly referred to as “FBAR.”

New FBAR Guidance and Proposed Regulations Issued

Katten Muchin Rosenman LLP
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USA
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March 4 2010

The IRS recently issued important guidance (Notice 2010-23 and Announcement 2010-16) concerning the FBAR filing requirements for individuals and fund managers

IRS memorandum finds loans to U.S. borrowers by foreign lender with U.S. agent are subject to U.S. taxation

Katten Muchin Rosenman LLP
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USA
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September 24 2009

The Associate Chief Counsel (International) of the IRS has issued a memorandum in which it concludes that a foreign corporation (“LoanCo”) is engaged in a U.S. trade or business and subject to U.S. taxation on its net income from loans made by LoanCo to U.S. borrowers under the following circumstances

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