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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


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 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”


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


IRS deadline for FBAR filings and voluntary disclosure for taxpayers with offshore accountsentities is rapidly approaching
  • Alston & Bird LLP
  • USA
  • June 15 2009

On May 6, 2009, the Internal Revenue Service published guidance, in the form of answers to 30 "frequently asked questions," about its recently announced voluntary disclosure settlement initiative for U.S. citizens and residents maintaining undeclared offshore bank accounts andor entities


New IRS focus on global high wealth industry
  • Alston & Bird LLP
  • USA
  • November 16 2009

On October 26, IRS Commissioner Douglas Shulman announced a new IRS unit formed to examine high-wealth individuals and their related entities


Additional deadline for voluntary disclosure program
  • Alston & Bird LLP
  • USA
  • November 16 2009

The IRS is considering imposing a deadline on information reports filed by individuals who have sought to voluntarily disclose assets held in offshore accounts before the special program deadline


U.S. lawmakers introduce Foreign Account Tax Compliance Act of 2009
  • Alston & Bird LLP
  • USA
  • November 16 2009

On October 27, 2009, Senator Max Baucus (D-MT) and Representative Charles Rangel (D-NY) introduced the Foreign Account Tax Compliance Act of 2009 (H.R. 3933, S. 1934) (the “Bill”) in the U.S. Congress


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"


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