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Federal District Court for Arizona rejects taxpayers' calculation of stock basis attributable to sale of stock from various insurance companies that had previously converted from a mutual based to a stock based company: Dorrance v. United States, 110 AFTR

Fox Rothschild LLP
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USA
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July 13 2012

A district court in Arizona has rejected cross motions for summary judgement filed by the taxpayers and the government in a tax refund case involving the amount of basis that could be established with respect to "equity" type rights that a policyholder had in several life insurance policies issued by a mutual insurance company which was demutualized into a stock company

Administrative and judicial review of tax controversies in Canada

Fox Rothschild LLP
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USA
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June 17 2012

Under authority of the Canadian constitution, the Income Tax Act subjects residents and resident businesses to tax on their worldwide income

Recent IRS hearings on FATCA implementation draws criticism from the banking and financial services sectors

Fox Rothschild LLP
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USA
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May 21 2012

The Foreign Account Tax Compliance Act (FATCA) is an important development in U.S. efforts to improve tax compliance involving foreign financial assets and offshore accounts

French Parliament recently enacts legislation for tax and disclosure obligations on trusts: France's version of FATCA

Fox Rothschild LLP
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USA
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March 20 2012

Legislation passed by the French Parliament in July 2011 imposes a new set of tax and disclosure obligations on trusts which have some connection to France

Commissioner issues temporary and proposed regulations on reporting foreign financial assets for individuals and domestic entities

Fox Rothschild LLP
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USA
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January 1 2012

The Internal Revenue Service has just published a first set of temporary regulations (T.D. 9567) under section 6038D requiring foreign financial assets of U.S. persons to be reported to the IRS for federal income tax purposes for tax years beginning after March 18, 2010

IRS issues fact sheet providing information on federal income tax return and foreign bank filing requirements

Fox Rothschild LLP
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USA
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December 16 2011

The federal government has known for some time that taxpayers who are dual citizens or dual residents of the United States and another country may have knowingly or innocently failed to timely file U.S. federal income tax returns

New Tax Relief Act of 2010 repeals gain recognition for certain transfers of property to nonresident aliens and grantor trusts

Fox Rothschild LLP
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USA
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December 24 2010

Transfers of appreciated property to foreign estates and to non-grantor foreign trusts are subject to federal income tax to the transferor as if disposed in a taxable transaction

Foreign tax credit provisions revised by recent legislation

Fox Rothschild LLP
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USA
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November 11 2010

This past August, President Obama signed into law several provisions which revised the foreign tax credit provisions

Department of Justice dismisses criminal charges against UBS

Fox Rothschild LLP
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USA
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October 22 2010

The Justice Department on October 22 dismissed criminal charges against the Swiss bank, UBS AG, which had been accused of helping thousands of Americans evade US taxes in the billions of dollars by concealing their assets in foreign accounts

Foreign Account Tax Compliance Act (FATCA) and its impact on exempt organizations

Fox Rothschild LLP
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USA
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October 5 2010

The bulk of the FATCA provisions go into effect with respect to payments made after 2012