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29 results found

Article

Morgan Lewis | USA | 30 Sep 2016

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

The recently proposed regulations, if finalized, would govern the treatment of RICs' income inclusions in respect of CFCs and PFICs for purposes of

Article

Morgan Lewis | USA | 1 Aug 2016

IRS Announces Fines Paid to FINRA Are Not Deductible

The Internal Revenue Service (IRS) in low-level advice recently announced its position that certain fines paid to the Financial Industry Regulatory

Article

Morgan Lewis | USA | 26 Aug 2011

Recent IRS notices provide supplemental FACTA guidance and phased-in implementation

The Internal Revenue Service (IRS) recently issued its second and third notices concerning the implementation of the Foreign Account Tax Compliance Act (FATCA).

Article

Morgan Lewis | USA | 11 Mar 2011

Final regulations regarding FBAR requirements for exempt organizations

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued final rules (RIN 1506-AB08) on February 24, 2011 regarding the requirements for certain U.S. persons to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) (the Final Regulations).

Article

Morgan Lewis | USA | 8 Dec 2010

IRS issues sourcing rules for “fails charges” that impact the application of U.S. withholding tax rules

On December 7, the Internal Revenue Service (IRS) issued new temporary regulations providing sourcing rules for "fails charges" that may arise in the delivery-versus-payment market for Treasury securities.

Article

Morgan Lewis | USA | 10 Mar 2010

Courts, IRS weigh in on mandatory conversion of terminated participants’ ESOP accounts

Plan sponsors of employee stock ownership plans (ESOPs) that have been submitted for a favorable determination letter know that the IRS is carefully reviewing plan provisions that provide for the mandatory conversion of a terminated participant's ESOP account balance from employer securities to cash.

Article

Morgan Lewis | USA | 26 Feb 2010

FinCEN and IRS issue guidance on FBAR filing requirements for certain U.S. persons

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued a Notice of Proposed Rulemaking (RIN 1506-AB08) on February 23 regarding the requirements for certain U.S. Persons to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).

Article

Morgan Lewis | USA | 4 Jan 2010

A New Year’s tax gift: additional year for short-term loan exception to IRC Section 956

On December 29, 2009, the Department of Treasury (the Treasury) and the IRS released Notice 2010- 12, which extends the 60-day short-term loan exception to Internal Revenue Code (IRC) Section 956 for an additional taxable year.

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