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Results: 1-10 of 26

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

New IRS focus on global high wealth industry

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 16 2009

On October 26, IRS Commissioner Douglas Shulman announced a new IRS unit formed to examine high-wealth individuals and their related entities

IRS chart clarifies separate Form 8938 and FBAR reporting requirements

  • Alston & Bird LLP
  • -
  • USA
  • -
  • 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

New Section 877A significantly alters expatriation tax regime

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 15 2008

On June 17, 2008, President Bush signed into law the Heroes Earnings Assistance and Relief Tax Act of 2008 (the “HEART Act”

Timeline extended for implementation of FATCA “stop tax haven abuse” legislation reintroduced

  • Alston & Bird LLP
  • -
  • 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

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”

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

New IRS guidance on FACTA: more positive than initial IRS guidance

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 15 2011

Account Tax Compliance Act provisions designed to detect U.S. persons who may be evading U.S. tax by holding income-producing assets through accounts at foreign financial institutions (FFIs) or other foreign entities

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

Government fails to prove taxpayer “willfully” concealed offshore bank accounts

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 20 2010

Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign Bank and Financial Accounts