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IRS releases Revenue Procedure 2010-19 relating to Canadian emigrants
  • Alston & Bird LLP
  • Canada, USA
  • April 15 2010

The IRS issued guidance for individuals who emigrate from Canada and who wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Revenue Procedure 2010-19


A two-minute self-examination concerning your estate planning
  • Alston & Bird LLP
  • USA
  • December 16 2014

Well-drafted estate plans are essential for managing your wealth while you are alive and distributing it after your death. Such an impactful set of


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


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


FBAR filing deadline June 30 some relief granted for prior year FBAR filings
  • Alston & Bird LLP
  • USA
  • June 17 2011

This advisory reminds employee benefit plan sponsors and plan personnel of the upcoming June 30, 2011, deadline for filing 2010 FBAR information statements


Timeline extended for implementation of FATCA “stop tax haven abuse” legislation reintroduced
  • Alston & Bird LLP
  • USA
  • August 15 2011

The Foreign Account Tax Compliance Act (FATCA), the government’s tool against offshore tax evasion, was scheduled to become effective on January 1, 2013


IRS announces 2011 offshore voluntary disclosure initiative in the form of 53 frequently asked questions and answers
  • Alston & Bird LLP
  • USA
  • February 18 2011

On February 8, 2011, the Internal Revenue Service (the "IRS") published guidance in the form of answers to 53 "frequently asked questions" in announcing its long-awaited follow-up to the Offshore Voluntary Disclosure Program that closed on October 15, 2009 (the "2009 OVDP"


New IRS guidance on FACTA: more positive than initial IRS guidance
  • Alston & Bird LLP
  • USA
  • April 15 2011

Account Tax Compliance Act provisions designed to detect U.S. persons who may be evading U.S. tax by holding income-producing assets through accounts at foreign financial institutions (FFIs) or other foreign entities


New Section 877A significantly alters expatriation tax regime
  • Alston & Bird LLP
  • USA
  • July 15 2008

On June 17, 2008, President Bush signed into law the Heroes Earnings Assistance and Relief Tax Act of 2008 (the “HEART Act”


U.S. estate planning for nonresident aliens from treaty countries - a comparison of Germany, Austria, France and the United Kingdom
  • Alston & Bird LLP
  • USA
  • May 17 2007

If an individual is not domiciled in the United States for estate and gift tax purposes (hereinafter referred to as a “nonresident alien”) and resides in a country with which the United States has an estate tax treaty, such a nonresident alien may avail himself or herself of estate planning techniques not available to other nonresident aliens, particularly if the treaty is one of the domicile-based treaties entered into since 1971 (as compared to the situs-based treaties entered into before 1971