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Results: 1-10 of 27

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”

Stop Tax Haven Abuse Act: if enacted, would have broad implications

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 15 2009

On March 2, 2009, Senator Carl Levin (D-MI) introduced the Stop Tax Haven Abuse Act

U.S. estate planning for nonresident aliens from treaty countries - a comparison of Germany, Austria, France and the United Kingdom

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 17 2007

If an individual is not domiciled in the United States for estate and gift tax purposes (hereinafter referred to as a “nonresident alien”) and resides in a country with which the United States has an estate tax treaty, such a nonresident alien may avail himself or herself of estate planning techniques not available to other nonresident aliens, particularly if the treaty is one of the domicile-based treaties entered into since 1971 (as compared to the situs-based treaties entered into before 1971

IRS deadline for FBAR filings and voluntary disclosure for taxpayers with offshore accountsentities is rapidly approaching

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 15 2009

On May 6, 2009, the Internal Revenue Service published guidance, in the form of answers to 30 "frequently asked questions," about its recently announced voluntary disclosure settlement initiative for U.S. citizens and residents maintaining undeclared offshore bank accounts andor entities

IRS announces settlement agreement between Switzerland and the U.S. (IR-2009-75)

  • Alston & Bird LLP
  • -
  • Switzerland, USA
  • -
  • September 16 2009

On August 19, 2009, the Internal Revenue Service (IRS) and the Justice Department announced that they had reached an agreement with UBS AG (UBS) regarding the IRS John Doe summons to obtain approximately 4,450 names of U.S. taxpayers with accounts in UBS

IRS releases Revenue Procedure 2010-19 relating to Canadian emigrants

  • Alston & Bird LLP
  • -
  • Canada, USA
  • -
  • April 15 2010

The IRS issued guidance for individuals who emigrate from Canada and who wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Revenue Procedure 2010-19

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

Additional deadline for voluntary disclosure program

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

The IRS is considering imposing a deadline on information reports filed by individuals who have sought to voluntarily disclose assets held in offshore accounts before the special program deadline

U.S. lawmakers introduce Foreign Account Tax Compliance Act of 2009

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

On October 27, 2009, Senator Max Baucus (D-MT) and Representative Charles Rangel (D-NY) introduced the Foreign Account Tax Compliance Act of 2009 (H.R. 3933, S. 1934) (the “Bill”) in the U.S. Congress

Guidance concerning foreign bank account (FBAR) filing requirements released

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 15 2010

On February 26, 2010, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department (“Treasury”) issued a Notice of Proposed Rulemaking proposing to amend the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR