Gabriel Quihuis

Gabriel Quihuis

Morgan Lewis

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FinCEN Extends Filing Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2017 to file the Report of Foreign Bank and Financial Accounts....more

6/22/2016 - Corporate Officers FBAR Filing Deadlines FinCEN Foreign Bank Accounts Reporting Requirements SEC Time Extensions

FBAR Proposed Regulations Expand Both Filing Exemption and Reporting

On March 1, the Financial Crimes Enforcement Network (FinCEN) issued proposed regulations that revise and clarify certain provisions in the rules regarding the filing of Reports of Foreign Bank and Financial Accounts (FBAR)....more

3/7/2016 - Exemptions FBAR FinCEN Foreign Financial Accounts Reporting Requirements

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs. On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more

1/6/2016 - FIRPTA Foreign Investment Internal Revenue Code (IRC) Pension Funds Protecting Americans from Tax Hikes (PATH) Act Real Estate Investments Registered Investment Companies (RICs) REIT SEC Shareholders Spinoffs

Treasury, IRS Extend Certain FATCA Transitional Rules

IRS Notice postpones several key deadlines and provides other relief. On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more

9/28/2015 - Amended Regulation FATCA FATCA Timeline Foreign Financial Institutions (FFI) GIIN Grandfathered Obligations Intergovernmental Agreements IRS Pro Rata Allocation Rule U.S. Treasury Withholding Requirements

FinCEN Again Extends Deadline for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more

1/27/2015 - FBAR FinCEN Foreign Bank Accounts IRS SEC

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

The IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more

5/8/2014 - Banks Enforcement FATCA FFIs Foreign Banks International Tax Issues IRS

Initial FATCA Registration/Withholding Dates Draw Near

Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms. The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more

4/11/2014 - FATCA FATCA Timeline FFI IRS

FinCEN Announces Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2015 to file the Report of Foreign Bank and Financial Accounts....more

1/14/2014 - Extensions FBAR Filing Deadlines FinCEN U.S. Treasury

Treasury Revises FATCA Implementation Timeline

IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...more

7/16/2013 - Delays FATCA FFI Foreign Banks IGAs IRS Tax Reform U.S. Treasury

IRS Releases “Start Construction” Guidance for Renewable Energy Facilities

Long-awaited guidance regarding eligibility for production or investment tax credits largely tracks guidance under the Section 1603 cash grant program....more

4/19/2013 - American Taxpayer Relief Act Begun Construction Test Investment Tax Credits IRS Physical Work Test Production Tax Credit Qualified Energy Facilities Renewable Energy Safe Harbors Tax Credits

Congress Extends 100% Gain Exclusion for Small Business Stock

Favorable tax treatment applies to certain acquisitions of qualified small business stock in 2012 and 2013 and may influence choice-of-entity decisions....more

1/11/2013 - Acquisitions Alternative Minimum Tax American Taxpayer Relief Act C-Corporation Capital Gains Choice of Entity Corporate Taxes Gain Exclusion Income Taxes Qualified Small Business Stock

FinCEN Announces Third Extension for Certain FBAR Filers

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

1/7/2013 - FBAR FinCEN Foreign Banks IRS SEC

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