Notice 2023-11, issued in December 2023, provided limited relief to certain foreign financial institutions (FFIs) that were not fully in compliance with the terms of their Model 1 FATCA Intergovernmental Agreement (IGA)....more
On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more
On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more
On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (88 FR 59576) that detail the information reporting requirements with respect to brokers of...more
On February 21, 2023, Treasury and the IRS issued T.D. 9972, finalizing regulations implementing the requirement to e-file certain information and tax returns. These regulations affect filers of partnership returns, corporate...more
Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more