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Results: 1-10 of 27

Sections 305 and 306 and tracking stock
  • Alston & Bird LLP
  • USA
  • February 25 2013

LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and


Treasury presents more FATCA regulations
  • Alston & Bird LLP
  • USA
  • March 15 2014

On February 20, 2014, the U.S. Treasury and IRS released two sets of regulations relating to the Foreign Account Tax Compliance Act (FATCA). The new


Manchester United ruling?
  • Alston & Bird LLP
  • USA
  • October 22 2012

LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351


IRS updates 2012 Offshore Voluntary Disclosure Program with new FAQs
  • Alston & Bird LLP
  • USA
  • July 15 2012

On June 26, 2012, the IRS released new frequently asked questions (FAQs) on the 2012 Offshore Voluntary Disclosure Program (OVDP) that was announced in January


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


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


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


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 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


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