We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 45

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


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


Final regulations implementing nonresident alien deposit interest reporting
  • Alston & Bird LLP
  • USA
  • May 15 2012

The United States has maintained a longstanding policy of not taxing bank deposit interest of nonresident aliens as a way in which to encourage foreign investment in U.S. banks


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


Industries react to FATCA notice in comment letters
  • Alston & Bird LLP
  • USA
  • December 15 2010

Enacted on March 18, 2010, as part of the HIRE Act, the Foreign Account Tax Compliance Act (FATCA) provisions require reporting of U.S. persons who hold accounts in foreign financial institutions or who own certain interests in foreign entities that hold such accounts


Senator Scott Brown declares opposition to $19 billion "bank tax"; House-Senate conference may reconvene
  • Alston & Bird LLP
  • USA
  • June 29 2010

Today, Senator Scott Brown (R-MA), one of the few Republicans to vote for passage of the financial reform bill, sent a letter to Senate Banking Committee Chairman Christopher Dodd (D-CT) and House Financial Services Committee Chairman Barney Frank (D-MA) declaring his opposition to the roughly $19 billion "bank tax" on large banks and hedge funds that is included in the recently reconciled Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act


Government fails to prove taxpayer “willfully” concealed offshore bank accounts
  • Alston & Bird LLP
  • USA
  • October 15 2010

In United States v. J. Bryan Williams, a Virginia District Court found that the Government had failed to meet its burden to establish that a taxpayer willfully failed to report his interest in foreign bank accounts that were omitted from the individual’s 2000 tax return


Government fails to prove taxpayer “willfully” concealed offshore bank accounts
  • Alston & Bird LLP
  • USA
  • October 20 2010

Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign Bank and Financial Accounts


Final rule regarding foreign bank account filing requirements released
  • Alston & Bird LLP
  • USA
  • March 7 2011

On February 23, 2011, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department (Treasury) issued the final rule (Final Rule) to amend the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR