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Article

Fox Rothschild LLP | USA | 15 Feb 2011

Internal Revenue Service announces second voluntary disclosure program for offshore bank accounts and international tax evasion

On Feb 8, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI 2011), which follows on the significant level of disclosures made in response to the 2009 Offshore Voluntary Disclosure Program (OVDP 2009).

Article

Fox Rothschild LLP | USA | 26 Oct 2010

Two items of note with regard to plan loans

In late September 2010, the Financial Accounting Standards Board (FASB) approved its position that participant loans from defined contribution plans (profit sharing, 401(k) and money purchase pension plans) should be classified, for financial reporting purposes, as receivables.

Article

Fox Rothschild LLP | USA | 8 Jan 2010

Section 409A plan document correction program relief provided for document failures in nonqualified deferred compensation plans

In Notice 2010-6, which was published in early January, the IRS at long last provided guidance as to how taxpayers may voluntarily correct certain document failures that otherwise would cause a nonqualified deferred compensation plan to contravene the requirements of Internal Revenue Code Section 409A, triggering severe income tax consequences.

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