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FATCA: private equity funds
  • Winston & Strawn LLP
  • USA
  • June 19 2012

The Foreign Account Tax Compliance Act (“FATCA”) increases the U.S. tax compliance burden for foreign financial institutions (called “FFIs” in FATCA-speak

Financial services legislative and regulatory update - November 14, 2011
  • Mintz Levin Cohn Ferris Glovsky and Popeo PC
  • European Union, USA
  • November 14 2011

With two weeks to go, all of Washington continues to try to figure out the ending to the most complicated choose your own adventure story

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

Passive foreign investment company rules: treatment of income from certain government bonds for purposes of the passive foreign investment company rules
  • Sullivan & Cromwell LLP
  • USA
  • July 2 2012

In an important notice responding to current economic conditions, the Internal Revenue Service has acknowledged that banks may be holding larger amounts of government securities than they ordinarily would, and that it does not intend this situation to cause them to be treated as “passive foreign investment companies,” a category that may discourage U.S. persons from investing in their shares

New guidance allows greater use of built-in losses in bank M&A deals
  • Hunton & Williams LLP
  • USA
  • October 10 2008

The Treasury Department and the IRS have issued favorable guidance under Internal Revenue Code Section 382 for banks engaging in merger and acquisition activities, as well as certain capital-raising efforts

Proposed legislation would reverse benefit to bank acquirers and restrict deductions on losses
  • White & Case LLP
  • USA
  • January 29 2009

Proposed legislation would reverse the recent concession by the United States Department of the Treasury (“Treasury”) that waived the limitation on the deduction of losses of a bank that undergoes an ownership change

Major tax incentive for bank purchases: IRS eliminates the limitation on banks' built-in losses post-purchase
  • Jones Day
  • USA
  • October 8 2008

On September 30, the IRS issued a notice that creates a major tax incentive for buying or making major investments in banks

Debt buy-backs - UK taxation change as of 14 October 2009
  • Cadwalader Wickersham & Taft LLP
  • USA
  • November 2 2009

On 14 October 2009, the UK government announced a major change to the UK tax legislation covering the buy-back of debts

Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued
  • Proskauer Rose LLP
  • USA
  • March 3 2010

On February 26, 2010, the Treasury Department published long-awaited, revised proposed regulations clarifying which taxpayers will be required to file the Report of Foreign Bank and Financial Accounts, Form TD F 90-22

Capital markets 2011 mid-year report
  • Torys LLP
  • Canada, USA
  • July 27 2011

To date, 2011 has been an exciting year in North American capital markets