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Results: 1-10 of 45

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


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


A surprise REIT election ruling
  • Alston & Bird LLP
  • USA
  • January 5 2015

A recent Chief Counsel Advice treated a REIT election for a disregarded LLC as causing a potential Section 351 exchange before the current owner


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 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


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


The Treasury and IRS ease up (a little) as FATCA approaches
  • Alston & Bird LLP
  • USA
  • April 15 2014

The Foreign Account Tax Compliance Act (FATCA), enacted by the 2010 HIRE Act, generally requires foreign financial institutions (FFIs) and


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