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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


Bipartisan Fiscal Commission holds first meeting
  • Alston & Bird LLP
  • USA
  • April 29 2010

The President's Bipartisan Fiscal Commission, which is charged with proposing solutions to the country's debt and deficit crisis, held its first meeting on Tuesday


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


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


U.S. lawmakers introduce Foreign Account Tax Compliance Act of 2009
  • Alston & Bird LLP
  • USA
  • November 16 2009

On October 27, 2009, Senator Max Baucus (D-MT) and Representative Charles Rangel (D-NY) introduced the Foreign Account Tax Compliance Act of 2009 (H.R. 3933, S. 1934) (the “Bill”) in the U.S. Congress


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


Treasury’s investigation of US clients of Swiss banks
  • Alston & Bird LLP
  • Switzerland, USA
  • December 15 2008

The U.S. Justice Department and the U.S. Treasury Department have increased their efforts to uncover U.S. taxpayers who are allegedly evading U.S. taxes by hiding assets in Switzerland


IRS will not challenge REMIC status for certain loan modifications made in connection with the Home Affordable Modification Program
  • Alston & Bird LLP
  • USA
  • April 13 2009

On April 10, 2009, the Internal Revenue Service (IRS) issued Revenue Procedure 2009-23 (the "Revenue Procedure") and Notice 2009-36 (the "Notice"), to provide guidance regarding the effects of the Home Affordable Modification Program (HAMP) on real estate mortgage investment conduits (REMICs) and certain trusts


IRS issues additional guidance under U.S. Treasury’s “Home Affordable Modification Program"
  • Alston & Bird LLP
  • USA
  • April 13 2009

On April 10, 2009, the Internal Revenue Service (IRS) issued Revenue Procedure 2009-23 and Notice 2009-36, to provide guidance regarding the effects of the Home Affordable Modification Program (HAMP) on real estate mortgage investment conduits (REMICs) and certain trusts