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Results: 1-10 of 36

FACTA update: IRS releases new regulations, new forms, and new IGAs
  • Morrison & Foerster LLP
  • USA
  • April 17 2014

We can't think of a better way to end Q1 2014 than by bringing you the year's first issue of Tax Talk. Although Tax Talk is now in its seventh year


IRS rolls out FATCA intergovernmental agreements
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

Since the United States announced an intergovernmental approach to FATCA compliance in its joint statement with five European countries earlier this


CoCo development
  • Morrison & Foerster LLP
  • USA
  • January 24 2013

2012 was an active year for issuers and investors in contingent convertible bonds or "CoCo"s. Most significantly in Q4 Barclays priced a $3 billion


IRS releases draft FFI Agreement
  • Morrison & Foerster LLP
  • USA
  • October 29 2013

On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI


After months of anticipation, final FATCA regulations released
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

On January 17, 2013, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") issued final regulations2 implementing


Treasury releases FATCA intergovernmental model agreements
  • Morrison & Foerster LLP
  • USA
  • August 7 2012

On July 26, 2012, the U.S. Treasury Department (“Treasury”) released two model agreements that reflect the intergovernmental approach outlined in Treasury’s February joint statement with France, Germany, Italy, Spain, and the United Kingdom as an alternative to complying with the Foreign Account Tax Compliance Act (“FATCA”


U.S. Treasury and JapanSwitzerland announce they will negotiate toward a third way for FATCA compliance
  • Morrison & Foerster LLP
  • Japan, Switzerland, USA
  • June 25 2012

As we have previously reported, the Foreign Account Tax Compliance Act (“FATCA”) is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope


2011 Report of Foreign Bank and Financial Accounts ("FBAR") due June 30
  • Morrison & Foerster LLP
  • USA
  • June 13 2012

We wanted to remind our clients that Treasury Form TD F-90 22.1 “Report of Foreign Bank and Financial Accounts” (commonly known as the “FBAR”) is due on June 30, 2012 with respect to the calendar year 2011


Treasury publishes highly anticipated “withholdable payment” FATCA regulations and outlines international cooperation alternative
  • Morrison & Foerster LLP
  • USA
  • April 30 2012

After months of waiting, the Treasury released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable payment” regulations on February 8, 2012


IRS announces phased implementation of FACTA
  • Morrison & Foerster LLP
  • USA
  • July 19 2011

On July 14, 2011, the Internal Revenue Service (“IRS”) and Treasury Department (“Treasury”) announced a phase-in schedule which effectively delays implementation of the Foreign Account Tax Compliance Act (“FATCA”) for one year and, in some cases, until 2015