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Pillsbury | USA, United Kingdom, OECD, etc. | 12 Mar 2018

Annual Compliance Obligations What you Need to Know

This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with


Alston & Bird LLP | USA | 1 May 2012

FATCA private fund executive summary

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.


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.


Gibson Dunn & Crutcher LLP | USA | 4 Nov 2011

IRS proposes regulations to ease tax burdens on government investment funds

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").


Mayer Brown | USA | 23 Sep 2011

FATCA tax risks for US investments

On March 18, 2010, the U.S. government adopted the “Hiring Incentives to Restore Employment Act”.


Alston & Bird LLP | USA | 17 Jun 2011

FBAR filing deadline June 30 some relief granted for prior year FBAR filings

This advisory reminds employee benefit plan sponsors and plan personnel of the upcoming June 30, 2011, deadline for filing 2010 FBAR information statements.


Loeb & Loeb LLP | USA | 6 Apr 2011

Ongoing tax litigation highlights the importance of putting steps in the proper order when creating a family limited partnership

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.


Patterson Belknap Webb & Tyler LLP | USA | 1 Apr 2011

Final FBAR rules some retirement plan relief but reporting obligations remain

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.


Stoel Rives LLP | USA | 11 Mar 2011

Relief recently provided for foreign bank account reporting (FBAR)

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.


Katten Muchin Rosenman LLP | USA | 7 Mar 2011

Fund managers with signature authority over foreign bank and security accounts will need to file an FBAR this year

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).

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