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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


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


International update: FATCA, FBAR, voluntary disclosure
  • Alston & Bird LLP
  • USA
  • June 15 2011

As has been previously discussed, the Foreign Account Tax Compliance Act (FATCA) enacted in March 2010 was designed to detect U.S. persons who may be evading U.S. tax by holding incomeproducing assets through accounts at foreign financial institutions (FFIs) or through other foreign entities (non-financial foreign entities or NFFEs


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


FATCA private fund executive summary
  • Alston & Bird LLP
  • USA
  • May 1 2012

The IRS recently issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that provide additional FATCA guidance on due diligence, withholding and reporting obligations, carve-outs and exceptions to FATCA’s applicability, and a new timeline for implementation


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


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 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


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