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IRS announces new dates for FATCA implementation
- Sidley Austin LLP
- -
- USA
- -
- November 2 2012
The IRS has announced that the following new timeline for the implementation of several provisions of the Foreign Account Tax Compliance Act (“FATCA”) will be adopted in final regulations and has also expanded the definition of “grandfathered obligation” under FATCA
New revenue procedure expands tax-safe modifications for REMIC-held commercial loans
- Sidley Austin LLP
- -
- USA
- -
- September 16 2009
On September 15, 2009, the Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") published Revenue Procedure 2009-45 ("Rev. Proc. 2009- 45”), expanding a REMIC’s ability to modify troubled, commercial loans without jeopardizing the REMIC’s tax status or exposing it to prohibited transaction taxes
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
New reporting requirements apply to FBAR filings due June 30, 2009
- Sidley Austin LLP
- -
- USA
- -
- June 16 2009
The deadline to file FormTD F 90-22.1, the Report of Foreign Bank and Financial Accounts (the “FBAR Form”), with the U.S.Treasury Department with respect to foreign bank, securities or other financial accounts held during the 2008 calendar year is June 30, 2009
IRS will not treat public-private investment funds as taxable mortgage pools, allowing the funds to issue tranched debt without incurring a corporate income tax
- Sidley Austin LLP
- -
- USA
- -
- August 28 2009
Rev. Proc. 2009-38 announces that the Internal Revenue Service (“IRS”) will not apply the taxable mortgage pool (“TMP”) rules to Public-Private Investment Funds (“Funds”
Modifying loans under the Treasury’s Home Affordable Modification Program will neither jeopardize holders’ tax status nor implicate prohibited transaction taxes
- Sidley Austin LLP
- -
- USA
- -
- April 14 2009
On April 10, 2009, the Internal Revenue Service (“IRS”) released Notice 2009-36 and Rev. Proc. 2009-23, which conclude that loan modifications made pursuant to the Home Affordable Modification Program (“HAMP”) will neither jeopardize the special tax status of securitization vehicles holding the modified mortgages nor cause the imposition of any prohibited transaction taxes
IRS provides relief from FBAR reporting for pre-2010 interests in hedge funds and private equity funds; FINCEN issues proposed FBAR regulations
- Sidley Austin LLP
- -
- USA
- -
- March 2 2010
On February 26, 2010, the IRS released Announcement 2010-16 and Notice 2010- 23, both relating to the reporting obligations on Form TD F 90-22 1, the Report of Foreign Bank and Financial Accounts ("FBAR"
Hybrid capital product development: Focusing on Tier 1 and other hybrid capital products
- Sidley Austin LLP
- -
- European Union, Global, USA
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- March 23 2010
It is our pleasure to provide you with the eleventh edition of Sidley's publication on hybrid capital product development
IRS issues private letter ruling on equity treatment of municipal bond fund’s liquidity enhanced preferred stock
- Sidley Austin LLP
- -
- USA
- -
- March 1 2011
A private letter ruling ("PLR") issued by the Internal Revenue Service ("IRS") on February 16, 2011, on the equity treatment of closed-end fund liquidity enhanced preferred stock, confirms that the IRS will continue following the principles of expired IRS Notice 2008-55, which allowed closed-end municipal bond funds to refinance traditional auction rate or remarketed preferred stock ("ARPS") with liquidity enhanced preferred stock, such as variable rate demand preferred stock ("VRDP"
IRS releases supplemental FATCA guidance
- Sidley Austin LLP
- -
- USA
- -
- April 21 2011
The IRS has issued supplemental guidance regarding recently enacted foreign financial account reporting requirements in the Internal Revenue Code under the Foreign Account Tax Compliance Act ("FATCA"
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