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Sections 305 and 306 and tracking stock
- Alston & Bird LLP
- -
- USA
- -
- February 25 2013
LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and
Manchester United ruling?
- Alston & Bird LLP
- -
- USA
- -
- October 22 2012
LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351
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
Taking advantage of tax exemptions before they may expire on December 31, 2012
- Alston & Bird LLP
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- USA
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- September 21 2012
The 2010 federal estate and gift tax law provided good news for wealthy taxpayers: a lower maximum tax rate of 35; estate, gift, and generation-skipping transfer tax exemptions of $5 million ($10 million for a married couple); and estate and gift tax “exemption portability,” which allows a surviving spouse to increase his or her own lifetime exemption by the exemption a predeceased spouse never used
IRS updates 2012 Offshore Voluntary Disclosure Program with new FAQs
- Alston & Bird LLP
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- USA
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- July 15 2012
On June 26, 2012, the IRS released new frequently asked questions (FAQs) on the 2012 Offshore Voluntary Disclosure Program (OVDP) that was announced in January
IRS chart clarifies separate Form 8938 and FBAR reporting requirements
- Alston & Bird LLP
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- USA
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- April 16 2012
As part of the Hiring Incentives to Restore Employment (HIRE) Act, the Foreign Account Tax Compliance Act established a new and distinct foreign asset disclosure regime under Section 6038D requiring specified persons that hold interests in “specified foreign financial assets” to attach Form 8938, the “Statement of Specified Foreign Financial Assets,” to the person’s annual federal tax or information return reporting certain information if the aggregate value of those assets exceeds certain threshold amounts
IRS provides guidance on reporting of specified foreign financial assets
- Alston & Bird LLP
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- USA
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- January 15 2012
The Internal Revenue Service published temporary regulations (T.D. 9567) on December 19, 2011, implementing Section 6038D, which provides that “specified individuals” who have an interest in “specified foreign financial assets” with a value of more than the applicable reporting threshold must attach new Form 8938, Statement of Specified Foreign Financial Assets, to their tax returns for tax years beginning after March 18, 2010
Timeline extended for implementation of FATCA “stop tax haven abuse” legislation reintroduced
- Alston & Bird LLP
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- USA
- -
- August 15 2011
The Foreign Account Tax Compliance Act (FATCA), the government’s tool against offshore tax evasion, was scheduled to become effective on January 1, 2013
FBAR filing deadline June 30 some relief granted for prior year FBAR filings
- Alston & Bird LLP
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- USA
- -
- June 17 2011
This advisory reminds employee benefit plan sponsors and plan personnel of the upcoming June 30, 2011, deadline for filing 2010 FBAR information statements
FATCA, FBAR, voluntary disclosure
- Alston & Bird LLP
- -
- USA
- -
- June 8 2011
To provide guidance to those subject to FATCA, the IRS issued Notice 2010-60 on August 27, 2010 (the “2010 Notice”), and Notice 2011-34 on April 8, 2011 (the “2011 Notice”
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- Jurisdiction - USA
- Workarea - Private Client & Offshore Services
- Firm Name - Alston & Bird LLP
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