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Winston & Strawn LLP | USA | 20 Sep 2011

Securities lending and tax

On September 15th, the Ninth Circuit addressed the tax consequences of certain securities lending programs.


Roetzel & Andress | USA | 8 Aug 2011

2011 Offshore Voluntary Disclosure Program - deadline: August 31, 2011

Over the past several years, the IRS has increased its efforts to police offshore accounts.


Fox Rothschild LLP | USA | 24 Jul 2011

Tax Court rules that securities transaction did not qualify under Section 1058: decision follows on the heels of the Tax Court's recent decisions under Section 1058 in anshutz (135 T.C. No.5) and Carroway (135 T.C. No. 3) decided last year

In Henry Samueli et al v. Commissioner, 132 T.C. No. 4 (2011), the Tax Court, per Judge Kroupa’s opinion for the majority, in response to the petitioners and respondent (IRS) filing of cross motions for summary judgment in a consolidated proceeding, upheld the Service’s deficiencies in income tax for denying the taxpayers interest deductions claimed on the underlying “margin loans” used to acquire the securities, were disallowed on the basis the purported payments of “interest” were not made with respect to an actual debt


Calfee Halter & Griswold LLP | USA | 16 Feb 2011

IRS renews voluntary disclosure program to report offshore accounts

The IRS and the Department of Justice have publicized several high profile prosecutions to remind U.S. taxpayers of the risk of failing to report offshore accounts.


McDermott Will & Emery | USA | 10 Dec 2010

Service denies tax deferral and long-term capital gains through basket option transaction

Advice Memorandum 2010-005, released on November 12, 2010, sets out the Internal Revenue Service's position on whether the purchased call option described therein should be respected as an option; treated as another form of a derivative transaction; or recast as, in substance, tax ownership of the underlying basket of securities.


Fox Rothschild LLP | USA | 19 Nov 2010

Federal law excludes 100 of gains on qualified small business stock acquired by December 31, 2010

On September 27, 2010, President Obama signed the Small Business Jobs Act of 2010 aimed at encouraging investment in small businesses.


Ballard Spahr LLP | USA | 23 Feb 2010

IRS offers blueprint for claiming stock losses as deductions

A newly released IRS letter ruling (PLR 201006003, Oct. 28, 2009) provides guidance on how a consolidated return group may obtain an ordinary loss deduction in liquidating an insolvent subsidiary.


Epstein Becker Green | USA | 20 Aug 2009

Time running out on IRS program for reporting foreign accounts

Time is running out on taxpayers who would like to take advantage of an IRS program that permits U.S. taxpayers who have failed to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts ("FBAR"), as well as other information returns related to foreign holdings, to cure the failure while avoiding substantial penalties.


Lowenstein Sandler LLP | USA | 10 Aug 2009

IRS extends FBAR filing deadline for certain taxpayers to June 30, 2010

Federal law requires that any U.S. person or entity with a financial interest in, or signature or comparable authority over, any foreign financial account file an annual Report of Foreign Bank and Financial Accounts ("FBAR") if the aggregate value of such accounts exceeds $10,000 at any time during the calendar year.


Kilpatrick Townsend & Stockton LLP | USA | 26 Jun 2009

IRS modifies FBAR reporting requirements for hedge fund and commingled similar investments due June 30, 2009

The IRS has recently adopted an expansive view of what may constitute a financial account subject to FBAR reporting duties.

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