MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue:

FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net Investment Income” Regs; CCA 201343019: Dividends From Cypriot Holding Company Entitled to Preferential Rates; CCA 201343020: Payments Made to Foreign Distributors Treated as Compensation; Potentially Subject to U.S. Withholding Tax; International Tax Reform; Court Dismisses Challenge to Interest-Reporting Regulations; IRS Resumes REIT Conversion Rulings; Pilgrim’s Pride v. Commissioner, 141 T.C. 17 (2013): Tax Court Holds Abandoned Stock Generates Capital Loss; Discharge of Acquisition Indebtedness Exclusion Ended December 31, 2013; and Events and Awards.

Excerpt from FATCA Developments: Treasury Concludes IGAS; IRS Finalizes FFI Agreement -

With 2013 rapidly coming to a close, the Government worked feverishly to conclude IGAs with a host of new countries, release a final version of the FFI Agreement and work out the kinks in its FATCA registration website.

Please see full issue below for more information.

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