News & Analysis as of September 19, 2024

Internal Revenue Service

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The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +

Final IRS Regulations on Transition from LIBOR to Other Reference Rates

Dechert LLP on 1/31/2022

The U.S. Department of the Treasury and the Internal Revenue Service on December 30, 2021, issued final regulations (“Final Regulations”) allowing a tax-free treatment of “covered modifications,” as defined, of certain...more

IRS Publishes Final IBOR Transition Regulations

Cadwalader, Wickersham & Taft LLP on 1/3/2022

On December 30, 2021, the Treasury Department and IRS issued final regulations to address the taxability of modifications that replace LIBOR or another interbank offered rate (an IBOR) with a qualified rate like SOFR....more

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

Akin Gump Strauss Hauer & Feld LLP on 10/8/2018

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

MoFo Tax Talk - Volume 8, Issue 2

Morrison & Foerster LLP on 8/7/2015

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

After Months of Anticipation, Final FATCA Regulations Released

Morrison & Foerster LLP on 1/30/2013

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 (“FATCA”). ...more

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