Grandfathered Obligations

News & Analysis as of

IRS Delays FATCA Implementation

On July 12, 2013, the IRS released Notice 2013-43 (the “Notice”), which sets forth a revised timeline for the implementation of the Foreign Account Tax Compliance Act (“FATCA”). The most significant development is that...more

The Employer’s Playbook for ACA Compliance: Ten Practical Strategies for 2014

The Affordable Care Act (a/k/a Health Care Reform, or the ACA) is complicated. While there is nothing in the ACA that requires any employer to provide group health care coverage to its employees, the failure to do so can come...more

Alabama Legislative Update – Week 10: Slow and Steady Movement by Senate and House

As the Alabama Legislature moves closer to adjournment, legislation is making slow but steady progress. Tuesday and Thursday marked the 21st and 22nd days of the 2013 Regular Session. With only eight legislative days left and...more

Treasury Issues Final FATCA Regulations

Introduction - On January 17, 2013, the Department of the Treasury (“the Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (the “Regulations”) under Sections 1471 through 1474 of the...more

Revisions to FATCA Implementation

IRS announces certain new time lines for implementation and further interpretive guidance. On October 24, the Internal Revenue Service (IRS) announced several key revisions to Foreign Account Tax Compliance Act...more

IRS Announces Extended FATCA Deadlines

On October 24, 2012, the U.S. Internal Revenue Service (IRS) issued Announcement 2012-42: Timelines for Due Diligence and Other Requirements Under FATCA (Announcement). The Announcement provides that final regulations (Final...more

U.S. Treasury/IRS Amend FATCA Rules And Extend Certain Deadlines

As we move toward the end of 2012, many non-U.S. financial institutions have been eager for information on how the Foreign Account Tax Compliance Act (FATCA) is going to be implemented. They are the entities which will have...more

A Collective Sigh of Relief: IRS Announces Revisions to Timelines for Due Diligence and Other Requirements under FATCA

Yesterday, in Announcement 2012-42, the Internal Revenue Service (IRS) announced its intention to modify proposed regulations issued in February 2012 by the IRS and Treasury Department that implement a set of statutory rules...more

Proposed Treasury Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

On February 8, 2012, the Internal Revenue Service (“IRS”) announced the release of proposed regulations (the “Proposed Regulations”) for the next phase of implementing reporting and withholding provisions of the HIRE Act...more

Final Proposed FATCA Regulations Issued

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on February 8, 2012 issued proposed regulations addressing the implementation of the Foreign Account Tax Compliance Act (“FATCA,” which was...more

Proposed Regulations Provide FATCA Compliance Guidance for Foreign Financial Institutions, Other Foreign Entities and U.S....

The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information...more

IRS and Treasury Department Publish Anticipated FATCA Guidance

Proposed Regulations under the Foreign Account Tax Compliance Act Issued February 8, 2012 On February 8, 2012, the U.S. Treasury Department and the Internal Revenue Service ("IRS") released widely anticipated proposed...more

An Intergovernmental Approach to FATCA: US Treasury Issues Joint Statement From the United States, France, Germany, Italy, Spain...

On February 8, 2012, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations under the Foreign Account Tax Compliance Act (“FATCA”). FATCA establishes a new US...more

Why You Still Need to Care about FATCA

In This Presentation: FATCA: Foreign Account Tax Compliance Act - History - Nuts and Bolts - Highlights of Proposed Regulations - Intergovernmental Agreement - Next Steps - Q&A Please see full...more

Next Phase of FATCA Guidance Arrives with Proposed Regulations and Announcement of Possible Intergovernmental Approach

On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more

FATCA Proposed Regulations Unveiled by Treasury

On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). In drafting the Proposed...more

Significant Developments for the Implementation of FATCA: The IRS and Treasury Department Release Proposed Regulations

On February 8, 2012, the Internal Revenue Service (IRS) and Treasury Department released long-awaited proposed regulations on a set of statutory rules commonly referred to as the Foreign Account Tax Compliance Act rules...more

"Highlights of Proposed Regulations Issued Under FATCA and Multijurisdiction Plan for Information Sharing"

On February 8, 2012, Treasury and the IRS issued comprehensive proposed regulations (Proposed Regulations) that would, when finalized, implement the Foreign Account Tax Compliance Act (FATCA), which was enacted in March 2010....more

PPACA and Employers: New and Grandfathered Group Health Plans

The Patient Protection and Affordable Care Act, as modified by the Reconciliation Act and Manager's Amendment imposes new responsibilities on employers of all sizes immediately and progressively through 2014. The majority of...more

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