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IRS provides guidance on reporting of specified foreign financial assets
  • Alston & Bird LLP
  • USA
  • January 15 2012

The Internal Revenue Service published temporary regulations (T.D. 9567) on December 19, 2011, implementing Section 6038D, which provides that “specified individuals” who have an interest in “specified foreign financial assets” with a value of more than the applicable reporting threshold must attach new Form 8938, Statement of Specified Foreign Financial Assets, to their tax returns for tax years beginning after March 18, 2010


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


Here they come: first FATCA intergovernmental agreement signed
  • Alston & Bird LLP
  • USA
  • October 15 2012

In July of this year, Treasury released a model intergovernmental agreement (IGA) that offered a work-around to foreign entities whose countries of residence have laws preventing the entities from complying directly with FATCA and reflected a cooperative intergovernmental approach to tackling international tax evasion


Taking advantage of tax exemptions before they may expire on December 31, 2012
  • Alston & Bird LLP
  • USA
  • September 21 2012

The 2010 federal estate and gift tax law provided good news for wealthy taxpayers: a lower maximum tax rate of 35; estate, gift, and generation-skipping transfer tax exemptions of $5 million ($10 million for a married couple); and estate and gift tax “exemption portability,” which allows a surviving spouse to increase his or her own lifetime exemption by the exemption a predeceased spouse never used


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


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


Stop Tax Haven Abuse Act: if enacted, would have broad implications
  • Alston & Bird LLP
  • USA
  • April 15 2009

On March 2, 2009, Senator Carl Levin (D-MI) introduced the Stop Tax Haven Abuse Act


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”


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