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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


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


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


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


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


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


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


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


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