Search results

Order by most recent / most popular / relevance

Results: 1-10 of 651

IRS voluntary disclosure program

Duane Morris LLP
-
Switzerland, USA
-
August 28 2009

On August 19, 2009, the Internal Revenue Service (IRS) and the U.S. Department of Justice announced a settlement agreement with UBS regarding certain accounts held at the bank by U.S. persons

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

TARP Capital Purchase Program Subchapter S corporation term sheet

Hunton & Williams LLP
-
USA
-
January 15 2009

On January 14, 2009, the United States Department of Treasury (“Treasury”) issued its much anticipated Summary Term Sheet detailing the terms for participation in Treasury’s Troubled Asset Relief Program’s Capital Purchase Program (“CPP”) by bank and bank holding companies that have elected to be taxed under Subchapter S of Chapter 1 of the U.S. Internal Revenue Code (the “Code”

Foreign bank accounts: immediate action may be required to avoid criminal prosecution

Dykema Gossett PLLC
-
USA
-
September 2 2009

After September 23rd, unless the IRS extends the deadline, the terms of settling with the IRS for failing to disclose a foreign account are likely to become less advantageous and criminal sanctions become more likely

IRS voluntary disclosure program for Swiss bank accounts to end Sept. 23

Day Pitney LLP
-
USA
-
September 3 2009

The Internal Revenue Service is set to end Sept. 23 its voluntary disclosure program that allows U.S. taxpayers to avoid criminal prosecution if they pay taxes, interest and penalties for the past six years, in addition to a penalty equal to 20 percent of the highest account balance

Beware of liabilities lurking in testamentary and charitable trusts

Reed Smith LLP
-
USA
-
May 7 2009

In an era of unprecedented bank mergers and consolidations, many bank trust officers and wealth managers may find themselves undertaking responsibility for hundreds, and in some cases, thousands of trusts formerly administered by another institutional fiduciary or agent

Proposed legislation would reverse benefit to bank acquirers and restrict deductions on losses

White & Case LLP
-
USA
-
January 29 2009

Proposed legislation would reverse the recent concession by the United States Department of the Treasury (“Treasury”) that waived the limitation on the deduction of losses of a bank that undergoes an ownership change

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
-
USA
-
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

Final regulations expand tax safe harbors for certain common modifications of REMIC-held commercial mortgage loans

Sidley Austin LLP
-
USA
-
September 23 2009

On September 15, 2009, theTreasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published T.D. 9463, finalizing regulations (the “New Regulations”) that expand a REMIC’s ability to make certain common modifications to commercial mortgage loans without jeopardizing the REMIC’s tax status or exposing it to prohibited transactions taxes

IRS announces new REMIC rules

Seyfarth Shaw LLP
-
USA
-
September 29 2009

On September 15, 2009, the United States Internal Revenue Service (IRS) released two significant pronouncements relating to modifications of loans held by real estate mortgage investment conduits (REMICs

next >

Search results

IRS voluntary disclosure program

Credit unions under attack

TARP Capital Purchase Program Subchapter S corporation term sheet

Foreign bank accounts: immediate action may be required to avoid criminal prosecution

IRS voluntary disclosure program for Swiss bank accounts to end Sept. 23

Beware of liabilities lurking in testamentary and charitable trusts

Proposed legislation would reverse benefit to bank acquirers and restrict deductions on losses

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

Final regulations expand tax safe harbors for certain common modifications of REMIC-held commercial mortgage loans

IRS announces new REMIC rules

Current Search

Suggested Facets

Author

Firm Name

Jurisdiction

Workarea