News & Analysis as of

U.S. Treasury’s Benchmark TIC SHL Survey and Implications for Investment Managers

In August 2014, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of foreign holdings of U.S. issuers’ securities on Treasury International Capital...more

FATCA and the Cyprus – US Connection

THE US DEPARTMENT OF TREASURY HAS ANNOUNCED that Cyprus and the US have reached agreement in substance as regards the Inter-Governmental Agreement for FATCA and Cyprus has consented to being included ...more

FIO Focus, Issue No. 52

Treasury's Inspector General Releases Audit Report for the Federal Insurance Office - On May 14, 2014, the Office of the Inspector General (OIG) of the U.S. Department of the Treasury released its audit report of the...more

FBAR Filing Deadline Approaching

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2013 must electronically file with the U.S. Treasury...more

Deadline: Foreign Bank Account Reports Due June 30, 2014

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

India Agrees “In Substance” to Model 1 FATCA IGA

The U.S. Treasury announced that on April 11, 2014, India agreed “in substance” to sign a Model 1 FATCA IGA with the US. The IGA would therefore require Indian financial institutions to report information on U.S. account...more

As Simple as Do-Re-Mi: Treasury and IRS Issue Final Rules on Employer Information Reporting under ACA

While no one would claim that understanding the Affordable Care Act (“ACA”) and all of its associated regulations is as simple as the chorus from a Jackson 5 song, the Treasury and the Internal Revenue Service announced final...more

Initial TIC B Forms Filing Deadline for Investment Managers on January 15, 2014

Beginning with the period ended December 31, 2013, the U.S. Department of the Treasury expanded the scope of the financial institutions required to report cross-border claims, liabilities and short-term securities holdings on...more

Tax-Exempt Hospitals: IRS Issues Proposed Revenue Procedure to Correct and Disclose Failure to Meet 501(r) Requirements

The Internal Revenue Service (“IRS”) on December 30, 2013 issued a proposed revenue procedure that outlines steps to correct and disclose failures to meet the requirements of new section 501(r) of the Internal Revenue Code...more

Treasury Department/IRS Issue Proposed Rules on Employer Reporting of Health Insurance Coverage Under the Affordable Care Act

In addition to imposing substantive requirements on health insurance issuers in the group and individual markets and employer-sponsored group health plans, the Patient Protection and Affordable Care Act (Act) imposes three...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

Proposed Employer Tax Rules Available For Obamacare

The U.S. Department of the Treasury and the Internal Revenue Service have published proposed rules establishing reporting requirements for employers and insurers under the Affordable Care Act (“ACA”), or Obamacare....more

Obama Administration Postpones Health Care Reporting And Penalties Until 2015

On Tuesday, July 2, the Treasury Department announced that the Administration will delay the Affordable Care Act’s mandatory employer and insurer reporting requirements for another year. These requirements will not take...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

Treasury Delays FATCA Deadlines by Six Months

On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more

Employers Face Compliance Options In Lights Of Delayed Implementation Of Pay Or Pay Mandate Under The ACA, But Other ACA...

On July 2, 2013, the Treasury Department’s announced that enforcement of the "Pay or Play" mandate under the ACA will be delayed until January 1, 2015. This announcement was followed by a brief notice from the IRS which...more

Large Employer Reporting Requirements and Penalties Mandated by Affordable Care Act Delayed One Year

The Treasury Department announced on Tuesday, July 2, 2013, that reporting requirements and penalties imposed on large employers under the Affordable Care Act (ACA) would be delayed one year, until January 1, 2015. ...more

Obama Administration Delays ACA Employer Reporting and Penalties for 2014

In a July 2, 2013, blog posting on the U.S. Department of the Treasury website titled "Continuing to Implement the ACA in a Careful, Thoughtful Manner," the Obama administration announced that it will provide an additional...more

Treasury Announces Delay in Implementation of ACA Employer and Insurer Reporting Requirements and Employer Shared Responsibility...

Responding to concerns expressed about the complexity of the new employer and insurer reporting requirements under the Affordable Care Act scheduled to take effect in 2014, the Department of the Treasury informally announced...more

10Qs and 10Ks Now Required to Include Transactions Subject to Economic Sanctions

Effective February 6, 2013, companies required to file quarterly and annual reports (10Qs and 10Ks) with the Securities and Exchange Commission (SEC) are required to include information about certain of their own and their...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

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

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

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