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Results: 1-10 of 88

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


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


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


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 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


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


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


Summary of the proposed FATCA regulations
  • Alston & Bird LLP
  • USA
  • March 15 2012

On February 8, 2012, the IRS issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that build upon prior FATCA notices issued by the IRS


REMIC tax concerns surrounding foreclosures
  • Alston & Bird LLP
  • USA
  • March 6 2012

A Real Estate Mortgage Investment Conduit (REMIC) is an entity employed to securitize loans secured by real property and that has been granted tax-favored status


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