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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

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

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

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

Credit union insurance ruled to produce UBTI

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 1 2007

These IRS Technical Advice Memorandums (TAMs) conclude that state chartered credit unions earn unrelated business taxable income (UBTI) by selling various types of insurance to depositorsmembers

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

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