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Senate passes foreign account tax legislation

USA - February 24 2010 The Senate passed a jobs bill on February 24, 2010 that includes provisions substantially similar to those of the Foreign Account Tax Compliance Act of 2009, or FATCA, a bill previously proposed in the House and Senate that targeted the use of offshore accounts by US persons to hide financial assets.

Laura M. Barzilai, Nicholas R. Brown, Robert M. Kreitman, Bridget R. O’Neill, Sharp Sorensen

IRS releases audit guidelines on equity swaps

USA - February 10 2010 On January 14, 2010, the IRS released an industry directive alerting its field offices that non-U.S. persons may be using abusive total return swaps to avoid U.S. withholding tax on dividends.

Jon Brose, Bridget R. O’Neill, John T. Schaff

Harsh withholding, carried interest rules offset cost of extenders

USA - December 9 2009 On December 7, 2009, Charles Rangel, chair of the House Ways and Means Committee, introduced the "Tax Extenders Act of 2009," which extends for one year certain provisions scheduled to expire at the end of 2009 and offsets the cost of the extensions with revenue from provisions that, in general, would tax partnership income from investment management services at ordinary income rates and would impose a 30% withholding tax on payments to foreign financial institutions that fail to comply with certain reporting obligations.

Laura M. Barzilai, Nicholas R. Brown, Robert M. Kreitman, Bridget R. O’Neill, Sharp Sorenson

IRS addresses trade or business implications of offshore lending

USA - September 24 2009 On September 22, 2009, the IRS Office of the Chief Counsel issued a memorandum addressing the issue of whether interest income is effectively connected with a foreign corporation’s trade or business within the United States as a result of loan origination activities conducted through an agent in the United States.

Jay H. Zimbler

Term Asset-Backed Securities Loan Facility

USA - August 18 2009 On August 17, 2009, the Federal Reserve Board and the Treasury Department announced their approval of the extension of the Term Asset-Backed Securities Loan Facility ("TALF") launched in March.

R.J. Carlson, James Y. Huang, Mark J. Kowal, Daniel M. Rossner