News & Analysis as of

IRS Offers FATCA Relief, Extending Registration Deadline and Expanding Intergovernmental Agreement List

On April 2, 2014, the U.S. Internal Revenue Service (IRS) issued Announcement 2014-17 (the Announcement), which provides certain FATCA relief. The Announcement extends from April 25, 2014 to May 5, 2014 the deadline by which...more

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

Deadlines Approaching for Employer Return Requirements for ISOs and ESPPs – Reporting Requirements for 2014

Section 6039 of the Internal Revenue Code of 1986, as amended (the "Code"), requires corporations to furnish information statements to their employees (including former employees) and to the Internal Revenue Service ("IRS")...more

Employers: 2014 Deadlines to Furnish ISO and ESPP Information Statements and Returns

Employers, from startups to public companies, need to be aware of the following requirements and take action by January 31st if they apply. Section 6039 of the Internal Revenue Code requires a corporation to furnish a...more

Annual Notices for ISOs and ESPPs due January 31, 2014

Each January, companies that grant incentive stock options (ISOs) are required to provide notices to current and former employees who exercised ISOs during the preceding calendar year. Similar notices must be given to current...more

December 2013 and January 2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

Employee Benefits Update: 2013 Year End Plan Tasks

As we approach the end of the year, employers and plan sponsors of qualified retirement plans and health and welfare plans should take time to meet various upcoming deadlines. Failure to comply with the deadlines may result...more

"Treasury and IRS Move to Implement FATCA as 2014 Start Date Approaches"

On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA). Congress enacted FATCA in 2010 as part of...more

IRS Proposes Rules Regarding Information Reporting Requirements Under Sections 6055 and 6056 of the Affordable Care Act

Starting in 2014, the Affordable Care Act requires that nonexempt individuals either maintain “minimum essential coverage” or pay an individual payment with their income tax returns. Minimum essential coverage may be...more

Health Care Reform Update -- September 9th, 2013

In This Issue: Leading the News; Implementation of the Affordable Care Act; Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; Other Health Care News; and Hearings and Mark-Ups...more

Now for Everything Else: What Employers Still Need To Worry About Between Now And 2015

For the past several months (and, in many cases, years), most large employers have been preparing for the consequences of offering (or not offering) their workforce health coverage and complying with the complexities...more

Employer Responsibility – Will You Pay or Play? Part II - The Variable Hour or Seasonal Employee Problem

Although the employer mandate has been delayed to 2015, employers shouldn’t relax too much because significant planning still needs to be done now. Beginning in 2015 large employers either must offer full-time employees...more

"CFTC Deadlines Loom for Commercial End Users"

End users of swaps should be aware of three impending deadlines for complying with new Commodity Futures Trading Commission (CFTC) regulations....more

Affordable Care Act Update IRS Issues Guidance on Delay of Employer Shared Responsibility Penalties and Reporting Requirements

On July 2, 2013, the Treasury Department made a surprise announcement that enforcement of the Employer Shared Responsibility Mandate, a provision of the Patient Protection and Affordable Care Act ("PPACA"), would be delayed...more

Health Care Reform Update: Employer Shared Responsibility Provisions Delayed Until 2015; Other Provisions on the Horizon

On July 10, 2013, the IRS issued a formal notice delaying the effective date of the employer shared responsibility provisions under the Patient Protection and Affordable Care Act (“PPACA”) until January 1, 2015 (or later, for...more

Monthly Benefits Update - July 2013

Health Care Reform: IRS Transitional Relief Delays Pay or Play Reporting and Penalties - As we reported in an alert on July 3, the IRS has provided transitional relief to employers that delays pay or play reporting and...more

PCORI Fee Payment and Filing Deadline is July 31, 2013

The Affordable Care Act has established a new annual fee, imposed on group health plans, which will be used to fund the Patient Centered Outcomes Research Institute. The amount of the fee is $1 times the average number of...more

FATCA Alert: US announces six month postponement to the implementation dates for FATCA - the impact on UK FIs

On 12 July, just one working day before the secure portal to be used by FFIs to register their status was due to go live, the US Internal Revenue Service ("IRS") issued Notice 2013-43 ("the Notice") announcing the delay to...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43, released on July 12, 2013, announces the Internal Revenue Service’s (the IRS) and the Department of the Treasury’s intent to amend final Treasury regulations implementing the U.S. Foreign Account Tax...more

U.S. Treasury Department Delays Enforcement of Employer Mandate and Reporting Requirements Under PPACA

As seen in many mainstream press reports, the Obama administration announced in early July that (1) the employer mandate and (2) certain reporting requirements under the Patient Protection and Affordable Care Act (PPACA) will...more

Treasury and IRS Extend FATCA Deadlines

Notice 2013-43 (http://www.irs.gov/pub/irs-drop/n-13-43.pdf), released on July 12, 2013, announces the Internal Revenue Service's (the "IRS") and the Department of the Treasury's intent to amend final Treasury regulations...more

IRS Postpones Key FATCA Deadlines by Six Months; Updated Ropes & Gray FATCA Timeline Attached

On July 12, 2013, the Internal Revenue Service ("IRS") issued Notice 2013-43 (the "Notice"), postponing a number of deadlines under the Foreign Account Tax Compliance Act ("FATCA"). In the Notice, the IRS made a number of...more

Extension of FATCA Withholding Start Date and Grandfathering End Date

On July 12, Treasury and the IRS announced that they intend to amend final Treasury regulations implementing the U.S. Foreign Account Tax Compliance Act (FATCA) to provide for a six-month extension to the start of FATCA...more

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

FATCA Deadlines Extended

On July 12, 2013, the U.S. Internal Revenue Service (IRS) issued Notice 2013-43 (Notice) which extends certain key deadlines for implementing FATCA, and provides guidance regarding the effect of these deadlines on FATCA...more

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