28 results found
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.
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.
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").
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.
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").
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).
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.