The Internal Revenue Service has joined several other jurisdictions in publishing guidance regarding the income tax consequences of certain convertible virtual currency transactions. IRS Notice 2014-21ii clarifies that...more
The US Department of the Treasury and the Internal Revenue Service have released what they refer to as the “last substantial package of regulations” necessary to implement the Foreign Account Tax Compliance Act (FATCA). ...more
On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more
The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA).
OECD RELEASES “BEPS” ACTION PLAN – A SWEEPING INTERNATIONAL TAX EFFORT TO COMBAT BASE EROSION AND PROFIT SHIFTING -
The OECD’s Committee on Fiscal Affairs has published its Action Plan to address Base Erosion and...more
The IRS has released Private Letter Ruling 201322009, which responds to a request for clarification on the proper application of certain “look-through” rules for purposes of determining whether a foreign corporation is a...more