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Global banks being audited

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 7 2013

All global banks currently being audited by the IRS, which have engaged in cross-border withholding planning for clients, should take careful notice of AM

The FATCA Model 2 intergovernmental agreement

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 15 2012

In late July, the Treasury released a Model 1 Intergovernmental Agreement (IGA) to facilitate foreign financial institutions’ (FFIs) compliance with FATCA reporting rules

IRS announces new guidance on FATCA timelines, gross proceeds and grandfathered obligations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 15 2012

On October 24, 2012, the IRS issued Announcement 2012-42, presenting additional guidance for effectuating the Foreign Account Tax Compliance Act (FATCA

2012 post-election advisory

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 9 2012

On January 2, 2013, $1.2 trillion in automatic, across-the-board spending cuts to defense and domestic programsknown as “sequestration”are set to begin as mandated by the Budget Control Act of 2011

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

International tax advisory - U.S. Treasury releases model FATCA intergovernmental agreement

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 15 2012

In February 2012, Treasury issued a joint statement with France, Germany, Italy, Spain and the United Kingdom regarding plans for an intergovernmental approach to implement the Foreign Account Tax Compliance Act (FATCA

IRS updates 2012 Offshore Voluntary Disclosure Program with new FAQs

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 15 2012

On June 26, 2012, the IRS released new frequently asked questions (FAQs) on the 2012 Offshore Voluntary Disclosure Program (OVDP) that was announced in January

FATCA update

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 15 2012

As reported in our March 15, 2012, Special Alert Advisory, the Internal Revenue Service on February 8, 2012, issued a massive set of proposed regulations under the Foreign Account Tax Compliance Act (FATCA

U.S.Netherlands Competent Authority agreement covering limited fund mutual accounts

  • Alston & Bird LLP
  • -
  • Netherlands, USA
  • -
  • June 15 2012

In late May 2012, the Competent Authorities of the United States and the Netherlands entered into an agreement to clarify application of the United States-Netherlands income tax treaty (the “Treaty”) with respect to U.S. source dividends and interest paid to a limited fund for mutual account (LFMA

Final regulations implementing nonresident alien deposit interest reporting

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 15 2012

The United States has maintained a longstanding policy of not taxing bank deposit interest of nonresident aliens as a way in which to encourage foreign investment in U.S. banks