This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with
The IRS recently issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) that provide additional FATCA guidance on due diligence, withholding and reporting obligations, carve-outs and exceptions to FATCA’s applicability, and a new timeline for implementation.
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.
On November 3, 2011, the IRS published new proposed Treasury Regulations providing guidance relating to the taxation of income of foreign governments from investments in the United States under Section 892 of the Internal Revenue Code of 1986, as amended (the "Code").
On March 18, 2010, the U.S. government adopted the “Hiring Incentives to Restore Employment Act”.
This advisory reminds employee benefit plan sponsors and plan personnel of the upcoming June 30, 2011, deadline for filing 2010 FBAR information statements.
Currently ongoing litigation between taxpayers and the government serves to remind us of some very important concepts when creating a family limited partnership or limited liability company.
BackgroundTo assist the federal government in its efforts to deter criminal tax, money laundering and terrorist activities, the United States Treasury Department, through its Financial Crimes Enforcement Network, has issued final regulations (the "FBAR Regulations") under the Bank Secrecy Act concerning reports of foreign financial accounts.
Recently, the IRS and the Financial Crimes Enforcement Network of the United States Treasury (FinCEN) each took steps to ease the FBAR reporting obligations of United States persons.
The Financial Crimes Enforcement Network (FinCen) recently finalized its Bank Secrecy Act regulations, which require U.S. individuals with signature or other authority over foreign accounts to file a Report of Foreign Bank and Financial Accounts (FBAR).