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Treasury issues final FATCA regulations
- White & Case LLP
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- USA
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- January 23 2013
On January 17, 2013, the Department of the Treasury (“the Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the
An intergovernmental approach to FATCA: US Treasury issues joint statement from the United States, France, Germany, Italy, Spain and the United Kingdom in connection with the issuance of proposed FATCA Regulations
- White & Case LLP
- -
- France, Germany, Italy, Spain, United Kingdom, USA
- -
- February 11 2012
On February 8, 2012, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations under the Foreign Account Tax Compliance Act (“FATCA”
New proposed Treasury regulations clarify the scope of the exemption from US taxation of foreign sovereigns
- White & Case LLP
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- USA
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- December 30 2011
The US Treasury Department has recently issued proposed regulations under Section 892 of the Code that provide welcome clarity with respect to whether non-US sovereigns and entities controlled by non-US sovereigns will be treated as engaged in commercial activity for US federal income tax purposes
Recent guidance delays effective date for FATCA compliance
- White & Case LLP
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- USA
- -
- July 15 2011
On July 14, 2011, in Notice 2011-53 (the "Notice"), the US Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued guidance outlining phased implementation of the new US withholding regime and information reporting requirements for certain accounts maintained by foreign financial institutions ("FFIs") (commonly referred to as the Foreign Account Tax Compliance Act provisions, or the "FATCA provisions"
Treasury issues supplemental FATCA guidance
- White & Case LLP
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- USA
- -
- April 14 2011
On April 8, 2011, in Notice 2011-34 (the "Notice"), the Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued supplemental guidance under Sections 1471 through 1474 of the Internal Revenue Code of 1986, as amended, which pertain to the new US withholding regime and information reporting requirements for certain accounts maintained by foreign financial institutions (commonly referred to as the Foreign Account Tax Compliance Act provisions, or the "FATCA provisions"
IRS issues proposed regulations on the federal tax classification of series and cells established by domestic series limited liability companies and domestic protected cell companies and foreign series or cells engaged in insurance business
- White & Case LLP
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- USA
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- September 30 2010
On September 13, 2010, the Internal Revenue Service ("IRS") issued proposed regulations that clarify the treatment for Federal tax purposes of the individual series, cells, or accounts established by organizations such as series limited liability companies, series partnerships, series trusts, protected cell companies, segregated cell companies, segregated portfolio companies, and segregated account companies (the "Proposed Regulations"
IRS issues preliminary guidance on new FATCA withholding tax regime
- White & Case LLP
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- USA
- -
- September 9 2010
On August 27, 2010, in Notice 2010-60 (the “Notice”), the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued preliminary guidance pertaining to the new US withholding regime and information reporting requirements for certain accounts maintained by foreign institutions, commonly referred to as the Foreign Account Compliance Act provisions (the “FATCA provisions”), that were enacted as part of the Hiring Incentives to Restore Employment Act (the “HIRE Act”) on March 18, 2010
Congress again considering changing the taxation of carried interest
- White & Case LLP
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- USA
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- December 7 2009
On Thursday December 3, House Ways and Means Committee Chairman Charles Rangel (D-NY) told reporters that legislation to extend dozens of popular expiring tax provisions will include two major revenue raisers to offset the revenue loss of the extenders
Recent IRS guidance serves as cautionary warning to offshore lenders
- White & Case LLP
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- USA
- -
- September 25 2009
On September 22, 2009, the IRS Office of the Chief Counsel issued a memorandum (the "Memorandum") which has broad application to offshore hedge funds that undertake lending activities, CDO and CLO issuers, and the investment managers of these entities
IRS extends FBAR filing deadline for certain US persons
- White & Case LLP
- -
- USA
- -
- August 10 2009
On August 7, 2009, the Internal Revenue Service (the "IRS") extended the deadline for certain US persons to file form TD F 90-22
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