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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

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

IRS will not challenge REMIC status for certain loan modifications made in connection with the Home Affordable Modification Program

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 13 2009

On April 10, 2009, the Internal Revenue Service (IRS) issued Revenue Procedure 2009-23 (the "Revenue Procedure") and Notice 2009-36 (the "Notice"), to provide guidance regarding the effects of the Home Affordable Modification Program (HAMP) on real estate mortgage investment conduits (REMICs) and certain trusts

IRS issues additional guidance under U.S. Treasury’s “Home Affordable Modification Program"

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 13 2009

On April 10, 2009, the Internal Revenue Service (IRS) issued Revenue Procedure 2009-23 and Notice 2009-36, to provide guidance regarding the effects of the Home Affordable Modification Program (HAMP) on real estate mortgage investment conduits (REMICs) and certain trusts

Treasury’s investigation of US clients of Swiss banks

  • Alston & Bird LLP
  • -
  • Switzerland, USA
  • -
  • December 15 2008

The U.S. Justice Department and the U.S. Treasury Department have increased their efforts to uncover U.S. taxpayers who are allegedly evading U.S. taxes by hiding assets in Switzerland

Congress reaches agreement on $787 billion stimulus package; House passes legislation by 246-to-183 vote

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 13 2009

Late last night House and Senate conferees reached agreement on a final $787 billion stimulus bill, H.R. 1, also known as the “American Recovery and Reinvestment Act” (ARRA), and the House approved the compromise bill this afternoon by a 246-to183 vote with not a single Republican voting in favor

Stimulus legislation contains important tax changes for corporate borrowers and banks

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 13 2009

The compromise economic stimulus legislation approved by the House earlier today contains numerous tax changes, several of which are likely to be important to corporate borrowers and to banks

Appeals Court rules against the IRS and affirms refund for National Westminster Bank PLC

  • Alston & Bird LLP
  • -
  • United Kingdom, USA
  • -
  • February 15 2008

On January 15, 2008, the U.S. Court of Appeals for the Federal Circuit affirmed a decision of the Court of Federal Claims that National Westminster Bank PLC (“NatWest”) was entitled to a refund of $65.7 million with interest for 1981-87