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Results: 1-10 of 27

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


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


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


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


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


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"


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


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


FATCA, FBAR, voluntary disclosure
  • Alston & Bird LLP
  • USA
  • June 8 2011

To provide guidance to those subject to FATCA, the IRS issued Notice 2010-60 on August 27, 2010 (the “2010 Notice”), and Notice 2011-34 on April 8, 2011 (the “2011 Notice”