News & Analysis as of

HIRE Act

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

by Dechert LLP on

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

by Shearman & Sterling LLP on

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

Delinquent International Information Tax Returns May Extend the Statute of Limitations on Your Entire Federal Tax Return

More and more, U.S. taxpayers are becoming aware of their federal tax reporting obligation for foreign financial accounts, interests and assets. With increased IRS enforcement, broader media coverage of international tax...more

"Financial Institutions Wrestle With FATCA Implementation"

Over the past year, financial institutions have wrestled with the challenges presented by the U.S. Foreign Tax Compliance Act (FATCA). Originally scheduled to take effect in 2013, the U.S. Treasury Department and IRS have...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

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

On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more

FATCA: Final Regulations Raise Questions for Trust Practitioners

by Butler Snow LLP on

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

After Months of Anticipation, Final FATCA Regulations Released

by Morrison & Foerster LLP on

BACKGROUND - On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations implementing the Foreign Account Tax Compliance Act...more

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

by Akerman LLP on

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

IRS Releases Draft Form to Certify Status Of Individuals for Withholding Under FATCA

by Akerman LLP on

On September 11, 2012, the Internal Revenue Service (“IRS”) released a new draft version of Form W-8 BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals). This Form is used...more

IRS Issues Draft Withholding Forms Conforming To FATCA

by Akerman LLP on

The Foreign Account Tax Compliance Act ("FATCA"), passed as part of the Hiring Incentives to Restore Employment (HIRE) Act enacted in March 2010, added a requirement which generally provides that a foreign financial...more

U.S. Taxation of Fideicomisos under the FATCA Rules

by Moskowitz LLP on

Overview of Fideicomisos If you own a home or a vacation home in Mexico, chances are that your property is held in a fideicomiso. A fideicomiso is a contractual arrangement that is arguably something in between a trust...more

Proposed FATCA Regulations Feature InterGovernmental Approach

by White & Case LLP on

Sections 1471 through 1474, commonly referred to as the Foreign Account Tax Compliance Act (FATCA) were originally enacted as a part of the Hiring Incentives to Restore Employment Act on 3/18/10. FATCA requires foreign...more

First FBAR, Now FATCA: New Information Reporting Requirements for U.S. Taxpayers with Foreign Financial Assets

by Foley Hoag LLP on

U.S. citizens, resident aliens and certain non-resident aliens who held “specified foreign financial assets” at any point during 2011 may be required to file IRS Form 8938 (Statement of Specified Foreign Financial Assets)...more

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

by McDermott Will & Emery on

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

Treasury Department Issues Proposed Regulations Under FATCA and Unveils Bilateral Agreements for Partner Countries With Respect to...

by Bracewell LLP on

This update is a follow-up to our May 6, 2010 publication, HIRE Act of 2010 - Increases Need for International Tax Compliance, with respect to the new information reporting obligations for foreign financial institutions...more

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