We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search

Refine your search

Content type

Tags

Author

28 results found

Article

White & Case LLP | USA | 4 Nov 2011

New proposed regulations provide helpful guidance for investments by sovereign wealth funds and foreign sovereigns

On November 3, 2011, the IRS published proposed regulations under Section 892 of the Code1 that provide helpful guidance, and answer several questions, regarding the extent to which a foreign sovereign, a sovereign wealth fund or other controlled entities will be exempt from US tax under Section 892 of the Code on their investments into the United States.

Article

White & Case LLP | USA | 20 Apr 2011

US Treasury issues final FBAR regulations

The Financial Crimes Enforcement Network ("FinCEN"), a bureau of the United States Department of the Treasury (the "Treasury"), recently amended the regulations requiring certain United States persons to file reports of foreign financial accounts on Form TD F 90-22.

Article

White & Case LLP | USA | 14 Apr 2011

Treasury issues supplemental FATCA guidance

On April 8, 2011, in Notice 2011-34 (the "Notice"), the Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued supplemental guidance under Sections 1471 through 1474 of the Internal Revenue Code of 1986, as amended, which pertain to the new US withholding regime and information reporting requirements for certain accounts maintained by foreign financial institutions (commonly referred to as the Foreign Account Tax Compliance Act provisions, or the "FATCA provisions").

Article

White & Case LLP | USA | 9 Sep 2010

IRS issues preliminary guidance on new FATCA withholding tax regime

On August 27, 2010, in Notice 2010-60 (the “Notice”), the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued preliminary guidance pertaining to the new US withholding regime and information reporting requirements for certain accounts maintained by foreign institutions, commonly referred to as the Foreign Account Compliance Act provisions (the “FATCA provisions”), that were enacted as part of the Hiring Incentives to Restore Employment Act (the “HIRE Act”) on March 18, 2010.

Article

White & Case LLP | USA | 18 Jun 2009

Recent IRS guidance may require US sponsors of offshore private equity and hedge funds to file FBAR

In October 2008, the United States Department of the Treasury (the "Treasury") updated and amended Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts ("FBAR").

Article

White & Case LLP | USA | 9 Apr 2009

Congress introduces legislation that would tax offshore hedge funds as US corporations

On March 2, 2009, Senator Carl Levin (D.-MI) introduced the Stop Tax Haven Abuse Bill of 2009 (the Bill).

Article

White & Case LLP | USA | 28 Feb 2007

IRS transitional guidance on employer stock diversification

Section 401(a)(35) of the Internal Revenue Code of 1986, as amended (the "Code"), and Section 204(j) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), were added by Section 901 of the Pension Protection Act of 2006 (the "Act") and provide that defined contribution plans must provide certain participants, beneficiaries and alternate payees ("applicable individuals") the right to divest employer securities in their accounts and reinvest such amounts in other investment options.

Previous page 1 2 3