Administrative Law, International Law & Trade, Tax Law

How Tobin Tax and certain regulatory duties affect Block Trades in Italy

by Iacopo Canino, Ferigo Foscari, Michael Immordino, Alessandro Seganfreddo | White & Case LLP on 1/17/2013

Italian Law No. 228 dated December 24, 2012, which approved the 2013 budget, contemplates, among others, a new tax applicable to certain financial transactions (the “Tobin Tax”). The Tobin Tax will apply to transactions,...more

Year-End Developments And Compliance Checklists

by Cole Beaubouef, Richard Bernstein, George Danenhauer, Marie DeFalco, David Goret, Peter Greene, Elaine Hughes, Allen Levithan, Matthew Magidson, Robert Minion, Scott H. Moss | Lowenstein Sandler LLP on 1/17/2013

Lowenstein Sandler’s Investment Management Group is pleased to provide you with (i) a summary of recent legislative and regulatory developments that impact the investment management community; and (ii) checklists of year-end...more

CRA Releases New APA Report

by Matthew Peters | Dentons on 1/15/2013

This is the eleventh year in which the CRA has issued such a report, which is generally intended to enhance taxpayer awareness of the APA program and to describe (i) current operational status, (ii) relevant changes, and...more

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

by Henry Bupel, Matthew Kohley, Jenny Longman | Patterson Belknap Webb & Tyler LLP on 1/11/2013

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

FinCEN Extends FBAR Filing Deadline

by BuckleySandler LLP on 1/9/2013

On December 26, FinCEN issued Notice 2012-2 to extend the deadline for certain filers to submit the Report of Foreign Bank and Financial Accounts (FBAR). FinCEN has extended this deadline several times in the past and the...more

This Week in Washington - January 4, 2013

by Patton Boggs LLP on 1/9/2013

In This Issue: - DOMESTIC POLICY MATTERS - The Fiscal Cliff Compromise. With Vice President Joe Biden and Senate Minority Leader Mitch McConnell (R-Kentucky) stepping in over the weekend to lead negotiations, a...more

UK Tax Law Changes May Affect Fund Industry

by Proskauer Rose LLP on 1/8/2013

Recently proposed changes in UK law could affect private investment funds that operate or have partners, employees or investments in the UK. Many of the proposed changes are included in the draft Finance Bill 2013, which was...more

FinCEN Announces Third Extension for Certain FBAR Filers

by Richard LaFalce, Charles Lubar, Gabriel Quihuis, Richard Zarin, William P. Zimmerman | Morgan Lewis on 1/7/2013

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

FBAR-The New Marriage Penalty

by Sanford Millar on 1/7/2013

For those U.S. taxpayers who are married to non-residents there is a new form of marriage penalty if the spouses filed joint returns. To be eligible to file joint returns an election must be made with the first joint return...more

Bureau Proposes Further Revisions to Remittance Transfer Rules

by Andrew Owens | Davis Wright Tremaine LLP on 1/4/2013

On December 31, 2012, the Consumer Financial Protection Bureau (“Bureau”) published in the Federal Register revisions (“Proposal”) to rules on international remittance transfers that the agency published in February 2012 and...more

This Week in Washington - December 21, 2012

by Patton Boggs LLP on 12/27/2012

In This Issue: - DOMESTIC POLICY MATTERS - The Fiscal Cliff Debate. On Monday evening, the White House proposed a compromise of raising taxes only on income earners above $400,000 and increasing the amount of...more

Global Derivatives Update: ESMA And Clearing, Italy’s Transaction Tax

by Felix Shipkevich | Shipkevich PLLC on 12/21/2012

A tax on equity derivatives transactions grew more likely in Italy this week, as the Italian Senate approved a budget containing the seeds of a Financial Transaction Tax (FTT)....more

Financial Services – Update on UK and European Regulatory Developments

by Dechert LLP on 12/20/2012

This update summarises current regulatory developments impacting the asset management sector in the UK and throughout the European Union. In this issue: - Part A – Regulation of Financial Markets - Part B –...more

FATCA – 2013 and Beyond

by Stuart M. Schabes | Ober|Kaler on 12/20/2012

Tax lawyer Stuart Schabes co-presented “FATCA – 2013 and Beyond” at The Perfect Storm: US Tax Legislation and IRS Compliance 2013, a program hosted by Philip Stein & Associates and ERM. The discussion included: -...more

Foreign Taxpayers Can Benefit Despite Proposed Regulations

by Jeffrey L. Rubinger | Bilzin Sumberg Baena Price & Axelrod LLP on 12/18/2012

Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more

EU Customs Practice Group - November 2012

by White & Case LLP on 12/15/2012

In This Issue: * EU CUSTOMS POLICY - MCC/UCC recast proposal * TARIFFS - Update on duty suspensions/tariff quotas - EU preferences adopted for Pakistan - FTA update * CLASSIFICATION -...more

IRS Expanding Offshore Enforcement

by Sanford Millar on 12/10/2012

Recently the Acting IRS Commissioner said: “While successful implementation of the Foreign Account Tax Compliance Act will assist the IRS in pursuing tax evaders, it is not the government’s sole answer to the long-term...more

FATCA Model II Agreement Released

by Jonathan E. Gopman, Elysa R. Merlin, Barbara E. Ruiz-Gonzalez, Sherwin P. Simmons, II | Akerman Senterfitt on 12/6/2012

The U.S. Department of Treasury ("Treasury") recently released its second model agreement (the "Model II Agreement") for countries to implement the Foreign Account Tax Compliance Act ("FATCA"). FATCA requires foreign...more

United States Signs Bilateral Agreements to Implement FATCA with Denmark and Mexico

by Jonathan E. Gopman, Elysa R. Merlin, Barbara E. Ruiz-Gonzalez, Sherwin P. Simmons, II | Akerman Senterfitt on 12/6/2012

The United States has entered into its second and third bilateral agreements regarding the implementation of FATCA with Denmark and Mexico, respectively. FATCA was enacted in 2010 as part of the Hiring Incentives to Restore...more

Understanding FATCA

by Joan C. Arnold | Pepper Hamilton LLP on 12/3/2012

In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more

IRS Announces Revised FATCA Implementation Timelines

by Richard J. Horne, Christina M. Iafe, Brian Silikovitz | Lowenstein Sandler LLP on 11/29/2012

The Foreign Account Tax Compliance Act (“FATCA”) was enacted in 2010 as part of an effort to combat tax evasion by U.S. taxpayers holding investments in offshore accounts and through offshore intermediaries. FATCA creates a...more

No More Tax Havens or Bank Secrecy

by Sanford Millar on 11/12/2012

On November 8, 2012 the Treasury announced that it was in the process of formalizing inter-governmental agreements with 50 countries to secure compliance with the disclosure provisions of the Foreign Account Tax Compliance...more

Effective Resolution of BRICS Country Transfer Pricing Disputes

by A. Tracy Gomes, Cym H. Lowell | McDermott Will & Emery on 11/12/2012

In the evolving world of international transfer pricing, it can be risky to assume that planning strategies to achieve the lowest possible effective tax rates, as encouraged by the operative provisions of the Organisation for...more

IRS Announcement Extends FATCA Timelines

by Akerman Senterfitt on 11/5/2012

On October 24, 2012, the Internal Revenue Service ("IRS") and the Department of Treasury ("Treasury") issued an announcement that extends certain timelines for the implementation of Foreign Account Tax Compliance Act (FATCA)....more

South Korean government cracks down on offshore accounts

by Moskowitz LLP on 10/31/2012

In the last 10 years, South Korea has seen an incredible surge in economic expansion. The country now represents the fourth largest economy in Asia, and the capital city of Seoul - particularly its Gangnam neighborhood - has...more

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Administrative Law › International Law & Trade › Tax Law