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Results: 1-10 of 45

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


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


Congress reaches agreement on $787 billion stimulus package; House passes legislation by 246-to-183 vote
  • Alston & Bird LLP
  • USA
  • February 13 2009

Late last night House and Senate conferees reached agreement on a final $787 billion stimulus bill, H.R. 1, also known as the “American Recovery and Reinvestment Act” (ARRA), and the House approved the compromise bill this afternoon by a 246-to183 vote with not a single Republican voting in favor


Stimulus legislation contains important tax changes for corporate borrowers and banks
  • Alston & Bird LLP
  • USA
  • February 13 2009

The compromise economic stimulus legislation approved by the House earlier today contains numerous tax changes, several of which are likely to be important to corporate borrowers and to banks


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


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


Appeals Court rules against the IRS and affirms refund for National Westminster Bank PLC
  • Alston & Bird LLP
  • United Kingdom, USA
  • February 15 2008

On January 15, 2008, the U.S. Court of Appeals for the Federal Circuit affirmed a decision of the Court of Federal Claims that National Westminster Bank PLC (“NatWest”) was entitled to a refund of $65.7 million with interest for 1981-87


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


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