We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
In cooperation with Association of Corporate Counsel
  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-10 of 41

IMF proposes bank taxes to fund future bailouts

  • Alston & Bird LLP
  • -
  • Global, USA
  • -
  • April 22 2010

On Tuesday, the International Monetary Fund (IMF) issued a report to G-20 governments proposing new taxes on banks in order to fund future bailouts, echoing initiatives proposed in the U.S., the U.K. and the E.U

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

FATCA private fund executive summary

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 1 2012

The IRS recently issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that provide additional FATCA guidance on due diligence, withholding and reporting obligations, carve-outs and exceptions to FATCA’s applicability, and a new timeline for implementation

Credit unions under attack

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 1 2009

We wrote in 2007 about a series of TAMs in which the IRS had asserted that various income items of exempt credit unions were taxable as unrelated business taxable incomemostly income from non-members and members not directly related to deposits of and lending to members

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

IRS announces settlement agreement between Switzerland and the U.S. (IR-2009-75)

  • Alston & Bird LLP
  • -
  • Switzerland, USA
  • -
  • September 16 2009

On August 19, 2009, the Internal Revenue Service (IRS) and the Justice Department announced that they had reached an agreement with UBS AG (UBS) regarding the IRS John Doe summons to obtain approximately 4,450 names of U.S. taxpayers with accounts in UBS

Planning for bank reorganizations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 1 2008

The Treasury plans to invest up to $250 billion to recapitalize the U.S. banking system by buying non-voting preferred stock and warrants to purchase common stock from a large number of banks, thrifts, bank holding companies and savings and loan holding companies

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

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

Senator Scott Brown declares opposition to $19 billion "bank tax"; House-Senate conference may reconvene

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 29 2010

Today, Senator Scott Brown (R-MA), one of the few Republicans to vote for passage of the financial reform bill, sent a letter to Senate Banking Committee Chairman Christopher Dodd (D-CT) and House Financial Services Committee Chairman Barney Frank (D-MA) declaring his opposition to the roughly $19 billion "bank tax" on large banks and hedge funds that is included in the recently reconciled Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act