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Results: 1-10 of 88

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


Credit unions under attack
  • Alston & Bird LLP
  • USA
  • September 1 2009

We wrote in 2007 about a series of TAMs in which the IRS had asserted that various income items of exempt credit unions were taxable as unrelated business taxable incomemostly income from non-members and members not directly related to deposits of and lending to members


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 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


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


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 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


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