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Results: 1-10 of 45

Foreign fund’s lending and underwriting activities constituted U.S. trade or business
  • Alston & Bird LLP
  • USA
  • January 16 2015

In Chief Counsel Advice 201501013, released early this month, the IRS concluded that a foreign fund was engaged in a U.S. trade or business based on


A surprise REIT election ruling
  • Alston & Bird LLP
  • USA
  • January 5 2015

A recent Chief Counsel Advice treated a REIT election for a disregarded LLC as causing a potential Section 351 exchange before the current owner


Regulators clarify tax allocation agreements
  • Alston & Bird LLP
  • USA
  • August 22 2014

On June 13, 2014, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System, and the Office of the


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


Credit unions under attack
  • Alston & Bird LLP
  • USA
  • September 1 2009

We wrote in 2007 about a series of TAMs in which the IRS had asserted that various income items of exempt credit unions were taxable as unrelated business taxable incomemostly income from non-members and members not directly related to deposits of and lending to members


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


2012 post-election advisory
  • Alston & Bird LLP
  • USA
  • November 9 2012

On January 2, 2013, $1.2 trillion in automatic, across-the-board spending cuts to defense and domestic programsknown as “sequestration”are set to begin as mandated by the Budget Control Act of 2011


Stimulus legislation contains important tax changes for corporate borrowers and banks
  • Alston & Bird LLP
  • USA
  • February 13 2009

The compromise economic stimulus legislation approved by the House earlier today contains numerous tax changes, several of which are likely to be important to corporate borrowers and to banks


Congress reaches agreement on $787 billion stimulus package; House passes legislation by 246-to-183 vote
  • Alston & Bird LLP
  • USA
  • February 13 2009

Late last night House and Senate conferees reached agreement on a final $787 billion stimulus bill, H.R. 1, also known as the “American Recovery and Reinvestment Act” (ARRA), and the House approved the compromise bill this afternoon by a 246-to183 vote with not a single Republican voting in favor