The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.
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The Department of the Treasury and the Internal Revenue Service issued final regulations, effective February 5, 2013, concerning the tax consequences of noncompensatory options and convertible instruments issued by a...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more
Last week, a group of U.S. Senators submitted a letter requesting swift clarification by the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) of language regarding the wind production tax...more
The IRS recently issued guidance in the form of Notice 2013-1, available here, that provides guidance on federal tax treatment of certain per capita payments made to members of Indian tribes. The background for the Notice is...more
The U.S. Treasury Department recently released regulations on the tax treatment of noncompensatory options issued by a partnership, as well as proposed regulations addressing the threshold question of when a partnership...more
Overview - The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations), effective February 5, 2013, concerning the tax consequences of noncompensatory...more
On January 17, 2013, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released long-awaited final regulations on the set of statutory rules commonly referred to as FATCA. As more fully described in...more
On January 17, 2013, the U.S. Treasury Department released final regulations implementing sections 1471 through 1474 of the Internal Revenue Code (the “Code”), commonly known as the Foreign Account Tax Compliance Act or...more
On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more
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
To make certain that 2013 will be as exciting as 2012, on January 2 the US Treasury issued proposed regulations under section 4980H of the Internal Revenue Code (“Code”), which was added to the Code by the Patient Protection...more
On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more
On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more
This week, the Treasury Department released the Final Rules for FATCA -- the agency regulations that work to implement and enforce the Foreign Account Tax Compliance Act...more
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
The U.S. Treasury Department recently released new guidance to assist employers (generally those with 50 or more full-time or full-time equivalent employees) in preparing and planning for the 2014 requirement to offer...more
The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. - On December 24, 2012, the U.S. Department of Labor (DOL) updated its 2012 Semi-Annual...more
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
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
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
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
On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account...more
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
On July 26, 2012, the Treasury Department released two versions of a model intergovernmental agreement (model IGA) for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA). One...more
The U.S. Department of the Treasury (Treasury) issued joint statements with the governments of Japan and Switzerland on June 21, 2012 outlining a new framework for foreign financial institutions (FFIs) in those countries to...more
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