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Results: 1-10 of 37

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


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


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


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


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


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


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