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Results: 1-10 of 26

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

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”

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

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

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”

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

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

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

IRS announces 2011 offshore voluntary disclosure initiative in the form of 53 frequently asked questions and answers

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 18 2011

On February 8, 2011, the Internal Revenue Service (the "IRS") published guidance in the form of answers to 53 "frequently asked questions" in announcing its long-awaited follow-up to the Offshore Voluntary Disclosure Program that closed on October 15, 2009 (the "2009 OVDP"