Witold Jurewicz

Witold Jurewicz

DLA Piper

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IRS private letter ruling on non-conventional real estate assets enables taxpayer to convert to REIT: key points

The Internal Revenue Service recently released a private letter ruling regarding the treatment of certain assets as qualifying “real estate” for real estate investment trust (REIT) purposes. That ruling effectively enabled...more

1/31/2015 - CFC Corporate Conversions Depreciation Foreign Personal Holding Companies GAAP IRS PFIC Popular Private Letter Rulings QEF Real Estate Investments REIT Section 965

FATCA regulations updated but deadlines loom

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

3/13/2014 - Deadlines FATCA IRS U.S. Treasury

Multinationals take note: Baucus releases US international tax reform proposal, welcomes stakeholder comments

Senate Finance Committee Chairman Max Baucus (D-Montana) has released the first of a coming series of detailed tax reform proposals, this one on international tax. Today, Baucus also released proposals on tax...more

11/21/2013 - Income Taxes Multinationals Shareholders Tax Reform U.S. Treasury

IRS releases long-awaited draft FFI Agreement and previews updates to FATCA regulations

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). ...more

11/7/2013 - FATCA FFI IGAs IRS U.S. Treasury Withholding Tax

Using the new FATCA registration website: FAQs for financial institutions

As we reported to you last week, the US Internal Revenue Service has opened the FATCA Registration Website as of August 19, 2013. This web-based system enables financial institutions to register themselves and their branches,...more

8/30/2013 - FATCA IRS Registration

IRS opens online FATCA registration system: financial institutions may now sign in

As foreshadowed in Notice 2013-43, the IRS has opened the FATCA Registration Website. The Website is a secure, web-based system that enables financial institutions (FIs) to register themselves and their branches, if...more

8/21/2013 - FATCA IRS Registration Websites

IRS announces six-month delay in FATCA implementation

On Friday, the US Treasury Department and the Internal Revenue Service announced a six-month extension to the start of the FATCA withholding and account due diligence requirements. ...more

7/15/2013 - Due Diligence FATCA FDAP FFI Foreign Banks IGAs IRS U.S. Treasury Withholding Requirements

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