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Results: 1-10 of 39

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

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

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

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

International update: FATCA, FBAR, voluntary disclosure

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 15 2011

As has been previously discussed, the Foreign Account Tax Compliance Act (FATCA) enacted in March 2010 was designed to detect U.S. persons who may be evading U.S. tax by holding incomeproducing assets through accounts at foreign financial institutions (FFIs) or through other foreign entities (non-financial foreign entities or NFFEs

Final regulations implementing nonresident alien deposit interest reporting

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

The United States has maintained a longstanding policy of not taxing bank deposit interest of nonresident aliens as a way in which to encourage foreign investment in U.S. banks

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

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