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Results: 1-10 of 45

Scapegoats: how foreign taxpayers’ credits & refunds could be limited by withholding agents’ non-compliance
  • Alston & Bird LLP
  • USA
  • May 19 2015

In Notice 2015-10 (the "Notice"), the IRS announced that it and the Treasury will issue regulations to limit credits or refunds for withholding taxes


IRS to limit credits and refunds for withheld taxes to amounts deposited by withholding agents
  • Alston & Bird LLP
  • USA
  • May 15 2015

In Notice 2015-10 (the "Notice"), the IRS announced that it and the Treasury will issue regulations to limit credits or refunds for certain


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


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


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


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


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