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Results: 1-10 of 45

Foreign fund’s lending and underwriting activities constituted U.S. trade or business
  • Alston & Bird LLP
  • USA
  • January 16 2015

In Chief Counsel Advice 201501013, released early this month, the IRS concluded that a foreign fund was engaged in a U.S. trade or business based on


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


IRS says income on Federal Reserve collateral of foreign bank must be allocated between ECI and non-ECI
  • Alston & Bird LLP
  • USA
  • July 15 2013

In a recently released Technical Advice Memorandum (TAM) 201325012, the IRS said that interest earned by a foreign bank on notes pledged as


Regulators clarify tax allocation agreements
  • Alston & Bird LLP
  • USA
  • August 22 2014

On June 13, 2014, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System, and the Office of the


IRS releases new FATCA guidance, including draft FFI Agreement
  • Alston & Bird LLP
  • USA
  • November 15 2013

In Notice 2013-69, the IRS introduced a long-awaited draft Foreign Financial Institution (FFI) Agreement and additional guidance under the Foreign


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


Appeals Court rules against the IRS and affirms refund for National Westminster Bank PLC
  • Alston & Bird LLP
  • United Kingdom, USA
  • February 15 2008

On January 15, 2008, the U.S. Court of Appeals for the Federal Circuit affirmed a decision of the Court of Federal Claims that National Westminster Bank PLC (“NatWest”) was entitled to a refund of $65.7 million with interest for 1981-87


Planning for bank reorganizations
  • Alston & Bird LLP
  • USA
  • November 1 2008

The Treasury plans to invest up to $250 billion to recapitalize the U.S. banking system by buying non-voting preferred stock and warrants to purchase common stock from a large number of banks, thrifts, bank holding companies and savings and loan holding companies


Credit union insurance ruled to produce UBTI
  • Alston & Bird LLP
  • USA
  • April 1 2007

These IRS Technical Advice Memorandums (TAMs) conclude that state chartered credit unions earn unrelated business taxable income (UBTI) by selling various types of insurance to depositorsmembers


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