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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


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


IRS announces settlement agreement between Switzerland and the U.S. (IR-2009-75)
  • Alston & Bird LLP
  • Switzerland, USA
  • September 16 2009

On August 19, 2009, the Internal Revenue Service (IRS) and the Justice Department announced that they had reached an agreement with UBS AG (UBS) regarding the IRS John Doe summons to obtain approximately 4,450 names of U.S. taxpayers with accounts in UBS


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


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


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


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


New IRS guidance on FACTA: more positive than initial IRS guidance
  • Alston & Bird LLP
  • USA
  • April 15 2011

Account Tax Compliance Act provisions designed to detect U.S. persons who may be evading U.S. tax by holding income-producing assets through accounts at foreign financial institutions (FFIs) or other foreign entities