We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 37

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


Guidance concerning foreign bank account (FBAR) filing requirements released
  • Alston & Bird LLP
  • USA
  • March 15 2010

On February 26, 2010, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department (“Treasury”) issued a Notice of Proposed Rulemaking proposing to amend the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR


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


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”


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


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


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


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